BLBB 2014 Legal Disclosures

BLBB 2014 Legal Disclosures

Set forth below are the 2014 required legal disclosures for BLB&B Advisors, LLC. If you have any questions or concerns about these disclosures, please do not hesitate to contact your portfolio manager.

Proxy Voting Policy
BLB&B Advisors, LLC will not vote proxies for securities held in client accounts. The client maintains authority and responsibility for the voting of proxies

Policy on Privacy of Consumer/Customer Non-public Information

The Gramm-Leach-Bliley Act of 1999 requires certain financial institutions to establish appropriate standards and policies to safeguard client records and information and to advise their clients of these standards and policies. These safeguards are intended to insure the security and confidentiality of client information and to protect against any unauthorized access or use. At Burke, Lawton, Brewer & Burke, we highly value our client relationships and we do not disclose any nonpublic personal information about our clients to anyone, except as permitted by law. Set forth below is a notice, as required by the Gramm-Leach-Bliley Act, summarizing our privacy policy. If you would like more information regarding our privacy policy, contact your account rep.

Information We Collect

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. Therefore, when you open an account, we will ask for information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. In addition, as investment advisor and broker/dealer, we collect nonpublic personal information about you from the following sources:

• Information we receive from you upon becoming a client or that is disclosed during the course of our relationship

• Information about your transactions with us, our affiliates, and others

Information We Disclose

We do not disclose any nonpublic personal information about you or our former clients, except as permitted by law or as authorized by you. To assist us in offering you services, we share information with companies that act for us on your behalf, such as data processing companies or brokerage clearing firms. These companies assist us in providing a particular service and are obligated to keep the information that we provide to them confidential.

Who Has Access to Your Personal Information

As investment advisor and broker/dealer, we restrict access to your personal and account information to those employees who need to know that information in order to provide services to you. We maintain physical, electronic, and procedural safeguards that protect your nonpublic personal information.

Custody of Assets Rule 206(4)-2

While BLB&B Advisors, LLC does not have physical custody of assets, it may be deemed to have custody of client accounts within the meaning of Rule 206(4)-2 under the Investment Advisors Act of 1940 due to specific situations where a Portfolio Manager may also act as a trustee on certain accounts. For this reason, an independent public accountant conducts an annual surprise examination of clients funds and securities that fall under these arrangements.

Part II ADV available

In accordance with current regulations governing investment advisors, please note that BLB&B Advisors, LLC has copies of Part II of its Form ADV available for client review. Part II of the Form ADV provides information about an investment advisor and its business. If you would like a copy of our ADV Part II or Form ADV Part II Brochure, please direct your request in writing to Laura W. Brewer, or stop by our office.

Best Execution

BLB&B Advisors, LLC is an SEC registered investment advisory firm pursuant to the Investment Advisors Act of 1940. On a periodic basis BLB&B Advisors, LLC systematically reviews the cost and quality of execution services received by its clients, including trade execution statistics, responsiveness to the investment advisor, financial stability of the broker-dealer, service quality and responsiveness to client concerns and specific needs. Clients of BLB&B Advisors, LLC are required to designate the brokerage firm through which their account transactions will be effected at the time each client signs an investment advisory contract. Clients should periodically review the terms of their brokerage agreement to ensure that such arrangements meet the client’s needs and are competitive in the market in relation to their needs and the services offered. In designating an executing broker, clients should also take into account services other than trade execution they may require. Clients are free to select the brokerage arrangement that best meets their requirements. BLB&B Advisors, LLC does not independently select brokers for clients and it remains the client’s obligation to enter into a relationship and negotiate terms with the broker of their choice. Any discounted commission rate available to the client will be dependent upon the client’s ability to negotiate such discounts with the broker they select. BLB&B Advisors, LLC does not negotiate commissions with any broker its clients may select. BLB&B Advisors, LLC has an affiliated broker-dealer, Burke, Lawton, Brewer & Burke, LLC (BLB&B). To the extent that clients select BLB&B as their broker-dealer, a potential conflict of interest exists based on the companies’ common ownership. BLB&B Advisor clients who utilize BLB&B as their broker receive a discount from the standard commission rates charged by BLB&B.

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