JMP Group LLC is an investment banking and asset management firm that provides investment banking, equity research, and sales and trading services to corporate and institutional clients as well as alternative asset management products and services to institutional and high-net-worth investors. JMP Group LLC conducts its investment banking and research, sales and trading activities through JMP Securities LLC; its hedge fund and other investment activities though Harvest Capital Strategies LLC; the underwriting and management of investments in senior secured debt through JMP Credit Advisors LLC; and the management of Harvest Capital Credit Corporation (NASDAQ: HCAP), a business development company that finances small and midsized businesses, through HCAP Advisors.

JMP Securities LLC is an affiliated company and subsidiary of JMP Group Inc. and is a registered broker-dealer and member of The Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). Harvest Capital Strategies LLC is an affiliated company and subsidiary of JMP Group LLC and is registered as an investment advisor with the U.S. Securities and Exchange Commission. JMP Credit Advisors LLC is an affiliated company and subsidiary of JMP Group LLC and is a manager of corporate debt employing active investment strategies in the loan, fixed income and structured products markets.

All references to “JMP” herein refer to JMP Group LLC.

Investment Protection Principles and Research Analysts’ Conflict-of-Interest Policies
Pursuant to FINRA Research Rule 2241 (formerly FINRA Rule 2711, the “Rule”), JMP Securities (“JMP”) has implemented policies and procedures to identify, manage and/or disclose the potential conflicts of interest between its Research, Investment Banking and Institutional Sales departments. Following is an excerpt of said policies and procedures:

• JMP’s Research analysts may not be subject to the supervision or control of any employee of its Investment Banking and Institutional Sales departments;

• JMP does not pay a Research analyst any bonus, salary or other form of compensation that is based upon a specific Investment Banking transaction;

• JMP and its employees are prohibited from offering, directly or indirectly, favorable research, a specific rating or a specific price target to a company or from threatening to change research, a rating or a price target as consideration or inducement for the receipt of business or compensation. As such, publication of research for any reason other than the professional obligation to provide good advice to institutional customers is against JMP’s policies and is in violation of the Rule;

• In the event that JMP decides to drop coverage of a company, a final note will be published outlining the reasons;

• The Director of Research and/or JMP’s Supervisory Analysts review and approve all research products; and

• JMP discloses in its research reports and requires its Research analysts to disclose during public appearances whether:

(1) JMP currently makes a market in this security of the subject company.

(2) JMP has received compensation for banking or other services rendered to the subject company in the past 12 months.

(3) JMP was manager or co-manager of a public offering of securities for the subject company in the past 12 months, and received compensation for doing so.

(4) JMP participated as an underwriting or selling group member of a public offering by the subject company in the past 12 months, and received compensation for doing so.

(5) JMP and/or its affiliates have obtained a position of at least 1% in the equity securities of the subject company during the ordinary course of its/their business/investments.

(6) An officer of JMP is a director or officer of the subject company.

(7) The Research analyst (as defined by the Rule) covering the subject company or a member of the Research analyst’s household has a financial interest in this company.

(8) The Research analyst (as defined by the Rule) covering the subject company or a member of the Research analyst’s household serves as an officer, director, or advisory board member of the subject company.

(9) The Research analyst (as defined by the Rule) covering the subject company has had discussions of employment with the company.

(10) JMP expects to receive OR intends to seek compensation for Investment Banking services from the subject company in the next 3 months.

(11) The subject company and a number of underwriters (including JMP), among others, are defendants in a class action lawsuit following the issuance of securities by the subject company. The subject company is indemnifying the underwriters (and JMP) in connection therewith pursuant to the terms of the applicable underwriting agreement(s).

JMP’s Compliance Department has adopted and implemented Written Supervisory Policies and Procedures to ensure JMP and its officers and employees adhere to the aforementioned policies.

SEC Rule 605
In compliance with SEC Rule 605, order execution information can be accessed by clicking the link below.

JMP Securities Rule 605 order execution information
(September 2013 to present)

SEC Rule 606
In compliance with SEC Rule 606, information regarding the routing of customer orders can be accessed by clicking the link below.

JMP Securities Rule 606 routing information
(3rd quarter 2013 to present)

National Instrument 24-101 Trade Matching and Settlement
An institutional trade matching statement endorsed by the Canadian Capital Markets Association can be accessed by clicking the link below.

View trade matching statement

Characteristics and Risks of Standardized Options
Information on the characteristics and risks of standardized options is furnished by The Options Clearing Corporation and can be accessed by clicking the link below.

View options disclosure materials

Payment for Order Flow
JMP Securities does not engage in any agreements for payment for routing order flow to or receiving order flow from any designated exchanges, market makers, broker-dealers or market centers; nor does it engage in any other arrangements that are required to be disclosed as defined in SEC rule 10b-10(d)(9). Certain market centers offer cash rebates for orders that provide liquidity to their books and charge fees for orders that extract liquidity from their books. Occasionally, the value of the credits received by JMP Securities from one or more such market centers may exceed the amount charged to JMP Securities. Under these limited circumstances, such payments would constitute payment for order flow.

Good-Til-Cancelled Orders
JMP Securities does not accept Good-Til-Cancelled orders from customers of its institutional trading desk; JMP Securities accepts only day orders from them. If such a customer sends JMP Securities a Good-Til-Cancelled order, it will be treated by JMP Securities as a day order in all respects. If you have any questions or concerns about this policy and practice, please contact your JMP Securities representative.

Extended Hours Trading Risk Disclosure
Pursuant to both FINRA and NASDAQ rules, JMP Securities is required to provide the following disclosures regarding risk associated with customer trading in the Pre-Market and Post-Market Sessions:

Risk of Lower Liquidity. Liquidity refers to the ability of market participants to buy and sell securities. Generally, the more orders that are available in a market, the greater the liquidity. Liquidity is important because with greater liquidity it is easier for investors to buy or sell securities, and as a result, investors are more likely to pay or receive a competitive price for securities purchased or sold. There may be lower liquidity in extended hours trading as compared to regular market hours. As a result, your order may only be partially executed, or not at all.

Risk of Higher Volatility. Volatility refers to the changes in price that securities undergo when trading. Generally, the higher the volatility of a security, the greater its price swings. There may be greater volatility in extended hours trading than in regular market hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price in extended hours trading than you would during regular markets hours.

Risk of Changing Prices. The prices of securities traded in extended hours trading may not reflect the prices either at the end of regular market hours, or upon the opening of the next morning. As a result, you may receive an inferior price in extended hours trading than you would during regular market hours.

Risk of Unlinked Markets. Depending on the extended hours trading system or the time of day, the prices displayed on a particular extended hours system may not reflect the prices in other concurrently operating extended hours trading systems dealing in the same securities. Accordingly, you may receive an inferior price in one extended hours trading system than you would in another extended hours trading system.

Risk of News Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular market hours. Similarly, important financial information is frequently announced outside of regular market hours. In extended hours trading, these announcements may occur during trading, and if combined with lower liquidity and higher volatility, may cause an exaggerated and unsustainable effect on the price of a security.

Risk of Wider Spreads. The spread refers to the difference in price between what you can buy a security for and what you can sell it for. Lower liquidity and higher volatility in extended hours trading may result in wider than normal spreads for a particular security.

Risk of Lack of Calculation or Dissemination of Underlying Index Value or Intraday Indicative Value (“IIV”). For certain derivative securities products, an updated underlying index value or IIV may not be calculated or publicly disseminated in extended trading hours. Since the underlying index value and IIV are not calculated or widely disseminated during the pre-market and post-market sessions an investor who is unable to calculate implied values for certain derivative securities products in those sessions may be at a disadvantage to market professionals.

Potential Risks of Hedge Fund Investing
Offers and sales of hedge fund or other investment products are not made by this site and are only made by an offering memorandum when, as and if provided by Harvest Capital Strategies and, in any case, are only provided to accredited investors (as defined in the Securities Act of 1933, as amended) and qualified clients (as defined in the Investment Advisers Act of 1940, as amended). Potential interested parties should be aware that investments in hedge funds, including funds of hedge funds, are highly speculative, illiquid and involve a substantial element of risk. Any potential investor in a hedge fund should be prepared and able to lose an entire investment without hardship to them.

Any potential interested parties should also be aware of the following general risks to hedge fund investing. All of the following are in addition to the specific risks that may be associated with any particular investment and should be considered in evaluating the merits and suitability of making such an investment:

Loss of Capital. Investors are at risk of losing all or a substantial amount of any investment.

Past Results. Past results are not a guarantee as to the future performance of an investment or a strategy.

Speculative Investment Practices. Among other things, hedge funds may engage in leverage and other speculative investment practices that may increase the risk of loss.

Illiquidity. Investments are subject to limitations on withdrawals that make fund interests relatively illiquid.

Infrequent Valuation Information. Funds managed by Harvest Capital Strategies are not required to provide frequent pricing or valuation information, and dissemination of tax information to investors may be delayed.

No Registration of Funds or Interests. Neither the funds managed by Harvest Capital Strategies nor the interests therein are registered with any regulatory authority, and Harvest Capital Strategies does not intend to so register them.

Limited Access to Information on Investments. Information regarding underlying investments in a fund of funds may be severely limited, and the manager may be unable to obtain additional or verify such information provided.

Fees and Expenses. The fees and expenses charged by hedge funds are typically higher than the fees charged by registered mutual funds.

Certain Tax Risks. An investment in a hedge fund may involve certain tax risks. In addition, particularly with respect to funds of funds, delays in manager reporting may require investors to seek extensions of the deadline to file their tax returns.

The foregoing does not purport to be a complete explanation of the risks involved in investing in hedge funds. A hedge fund’s offering materials typically describe the risks and conflicts of interest relating to an investment in the fund. Each prospective investor who is qualified by Harvest Capital Strategies and receives these documents is urged to read them carefully to determine whether an investment in such fund is suitable for such investor in light of, among other things, such investor’s financial situation, need for liquidity, other investments and other general considerations.

Material, Non-Public Information
JMP Securities has policies and procedures in place reasonably designed to prevent the unauthorized use and disclosure of material, non-public information about securities issuers, pending research reports and other confidential data. These policies are intended to ensure that all information provided by JMP Securities to others is done so appropriately and in accordance with all applicable laws, rules and regulations.

Privacy Notice
In accordance with the Federal Financial Privacy Law (Gramm-Leach-Bliley Act, Nov. 1999), the following are JMP’s privacy policies applicable to non-public personal information gained from this website and to its business relationships in general:

Collecting Information
In the course of our relationship with you, we receive or develop information about you necessary to better service your account and your financial needs. This information may include: information you provide to us orally or on applications or other forms; information we develop about you in the course of providing our services to you, such as your account balance(s), the assets that we manage and the transactions we place on your behalf; and technical information we gather through your access to our website.

Protecting Information
As a general rule, we do not sell, share or otherwise disclose this private information with others unless such sharing of information is necessary to provide our services to you. For instance, there may be sharing of information between the subsidiaries of JMP, where each subsidiary is rendering a service to a customer common to both. Furthermore, we share information with certain third parties, such as our clearing agent, custodian, administrators, prime brokers, attorneys and auditors who, in the ordinary course of providing their services to us, may require access to information containing your non-public personal information. In addition, we may disclose your non-public personal information to others with your consent, where required by law or judicial process (such as a court order), or otherwise to the extent permitted under the Federal Financial Privacy Law.

We restrict access to your non-public personal information to those associates who need to know such information in order to provide services to you. If we are not comfortable that a service provider is already bound by duties of confidentiality (i.e., attorneys and auditors), we will require contractual assurances that the service provider will maintain the confidentiality of any of the information obtained from us. In addition, we maintain physical, electronic and procedural safeguards to protect your non-public personal information. We continually assess new technology and upgrade our system when appropriate to better protect information.

PATRIOT Act
In accordance with the USA PATRIOT Act and other regulations applicable to it, JMP advises users of its website that it will fully comply with any and all regulations which may be promulgated by the U.S. Treasury Department under the USA PATRIOT Act, including those that encourage financial institutions to share information with regulatory agencies and law enforcement about individuals or organizations that may be “reasonably suspected based on credible evidence” of engaging in terrorist acts or money laundering. Accordingly, any information provided to JMP may be provided to regulatory, government or law enforcement agencies if requested or if deemed appropriate by JMP.

Contact Us
If you have any questions about our practices with respect to your non-public personal information, you may write to us at 600 Montgomery Street, Suite 1100, San Francisco, CA 94111 or call us at (877) 263-1333.

Securities Investor Protection Corporation (SIPC)
JMP Securities is a member of SIPC.  For more information or to obtain a brochure about this program, please go online to http://www.sipc.org/.  Alternatively, SIPC can be reached by phone at (202) 371-8300, by fax at (202) 371-6728, by email at asksipc@sipc.org, or by mail at Securities Investor Protection Corporation, 805 15th Street, N.W., Suite 800, Washington, DC 20005-2215.