CUSTOMER PRIVACY POLICY: 2012

Pursuant Regulation S-P

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AT RODMAN & RENSHAW WE RECOGNIZE THE IMPORTANCE OF PROTECTING YOUR PRIVACY
AND WE HAVE POLICIES IN PLACE TO MAINTAIN THE CONFIDENTIALITY AND SECURITY OF YOUR
PERSONAL INFORMATION. THE FOLLOWING POLICY IS DESIGNED TO HELP YOU UNDERSTAND
WHAT INFORMATION WE COLLECT FROM YOU AND HOW WE USE THAT INFORMATION TO
SERVE YOUR ACCOUNT.


CONFIDENTIALITY AND SECURITY
WE RESPECT ACCESS TO NONPUBLIC INFORMATION, PERSONAL INFORMATION ABOUT YOU, TO
THOSE EMPLOYEES AND AGENTS WHO NEED TO KNOW THAT INFORMATION IN ORDER TO
PROVIDE PRODUCTS AND SERVICES TO YOU. WE MAINTAIN PHYSICAL, ELECTRONIC AND
PROCEDURAL SAFEGUARDS TO PROTECT YOUR NONPUBLIC, PERSONAL INFORMATION.

CATEGORIES OF INFORMATION THAT RODMAN & RENSHAW DISCLOSES AND PARTIES TO
WHOM IT IS DISCLOSED

WE DO NOT DISCLOSE ANY NONPUBLIC, PERSONAL INFORMATION ABOUT OUR CUSTOMERS OR
FORMER CUSTOMERS TO ANYONE, EXCEPT AS PERMITTED BY LAW.


CATEGORIES OF INFORMATION THAT RODMAN & RENSHAW COLLECTS

WE COLLECT NONPUBLIC, PERSONAL INFORMATION ABOUT YOU FROM THE FOLLOWING
SOURCES:
1) INFORMATION WE RECEIVE FROM YOU ON APPLICATIONS OR OTHER FORMS.
2) INFORMATION ABOUT YOUR TRANSACTIONS WITH OUR AFFILIATES AND US.


OPTING OUT

PLEASE BE AWARE THAT YOU HAVE THE RIGHT TO MAINTAIN THE PRIVACY OF YOUR
NONPUBLIC, PERSONAL INFORMATION. SHOULD OUR POLICY CHANGE, WE WILL NOTIFY YOU
AND AT THAT TIME, YOU MAY NOTIFY US, IN WRITING, IF YOU WISH THAT YOUR INFORMATION
NOT BE USED FOR ANY OTHER PURPOSE THAN MAINTAINING YOUR ACCOUNT WITH OUR FIRM.