Policies & Disclosures POLICIES & DISCLOSURES OF NORTHLAND SECURITIES, INC. AND AFFILIATED COMPANIES OF NORTHLAND CAPITAL HOLDINGS, INC. Account Terms of Service Northland Privacy Policy Northland Account Terms & Conditions Northland Client Fee Schedule (Effective 5/1/2018) Business Continuity Plan FINRA Rule 4370 requires a firm to disclose how its Business Continuity Plan addresses possible business disruption in various scenarios and its response to those scenarios. Business Continuity Plan Summary Northland Account Terms & Conditions Customer Communications: Text Messaging Customer Identification Program Northland’s Customer Identification Program (CIP) Electronic Delivery of Documents Information e-Delivery of Client Documents Email Disclosure Corporate Disclosure Regarding Email Usage Extended Hours Trading Risk Extended Hours Trading Risk Disclosure Statement Fiduciary Acknowledgement for Covered Retirement Accounts When Northland Securities and your Financial Representative provide investment advice regarding your retirement plans or individual retirement accounts, we acknowledge we are fiduciaries with the meaning of Title I of the Employee Retirement Income Security Act and/or Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we are compensated creates some conflicts with your interest, so we operate under a special rule that requires us to act in your best interest, and not put our interest ahead of yours. Fiduciary Acknowledgement for Covered Retirement Accounts FINRA BrokerCheck Website Northland Securities is a Member of FINRA and SIPC, and Registered with SEC and MSRB. BrokerCheck is a free tool which is part of FINRA’s ongoing efforts to help investors make informed choices about brokers (investment representatives), and brokerage firms. BrokerCheck also provides information about formerly registered brokers, who although no longer registered in the securities industry, may work in other financial services industries. The information contained in BrokerCheck is collected through FINRA’s registration process. FINRA BrokerCheck Financial Industry Regulatory Authority (FINRA) First National of Nebraska, Inc. (FNNI) Investments and Insurance Products: Not a Deposit | Not Guaranteed by the Bank or its Affiliates | Not FDIC Insured | Not Insured by Any Federal Government Agency | May Go Down in Value | Not a Condition to Any Banking Service or Activity Northland Securities, Inc., Member FINRA/SIPC, Registered with SEC and MSRB, is a diversified financial services firm offering wealth management, public finance, municipal advisory, and equity and fixed income capital markets services. Northland Securities, Inc., is also a SEC Registered Investment Adviser, doing business as Northland Asset Management offering investment advisory services. Fixed and variable annuities and other insurance products are offered through N Land Insurance Services (License # 6007398) in California and through Northland Securities, Inc. in all other states where it is licensed to do business. Insurance products are underwritten by unaffiliated insurance companies. Northland Securities, Inc., is a subsidiary of Northland Capital Holdings, Inc. First National of Nebraska, Inc., is the parent company of Northland Capital Holdings, Inc. and First National Bank of Omaha. Clearing services for Northland Securities are provided by Pershing LLC, Member FINRA, NYSE, and SIPC, a wholly-owned subsidiary of BNY Mellon. License and Registration Disclosure Registered Representatives of Northland Securities only transact business in states where they are properly registered, or excluded or exempted from registration requirements. Response to, or contact with, residents of other states will only be made upon compliance with applicable licensing and registration requirements. The information in this website is for U.S. residents only and does not constitute an offer to sell, or a solicitation of an offer to purchase, brokerage services to/from persons outside of the U.S. We reserve the right to require proof of residence from any user accessing this site and requesting information. It is not intended for use by, or to provide any information to investors outside of the U.S., as they are subject to securities and tax regulations within their applicable jurisdictions that are not addressed on this site. Municipal Securities Municipal securities generally are defined as direct obligations issued by a state, county, city, or any of their political subdivisions, such as a school district or a housing authority. Repayment of municipal securities depends on the ability of the issuer or the project backing such securities to generate taxes or revenues. Like other Fixed Income securities, municipal securities are subject to risks, such as call risk, credit risk, interest rate risk, and liquidity risk. Tax implications are another consideration that an investor will need to evaluate when investing in municipal securities. Northland does not give tax advice; therefore, investors will need to consult with their tax advisor. Your Financial Representative can discuss any markup or commission which may apply to a sale of a municipal security. Specific risks related to an individual municipal issue are listed in the official statement that discloses the complete information of the project and can be found on MSRB’s EMMA website (link below). Links to More Information: Municipal Securities Rulemaking Board (MSRB) The municipal securities investor brochure is available by telephone request at (202)838-1500 or at MSRB’s website: MSRB’s Information for Municipal Securities Investors Brochure Please see the referenced SEC Investor Alert about investing in Municipal Bonds: Investor.gov> Municipal Bonds Official statements can be found on MSRB’s EMMA website: MSRB’s Electronic Municipal Market Access (EMMA) FINRA’s Market Data Center also offers price and trade information. MSRB Northland Securities is a Member of FINRA and SIPC, and Registered with SEC and MSRB. Information regarding the Municipal Securities Rulemaking Board (MSRB) rules protecting investors and how to file a complaint with an appropriate regulatory authority are available in a MSRB investor brochure. The investor brochure is available at website address http://msrb.org/msrb1/pdfs/MSRB-Investor-Brochure.pdf or by telephone request at (202)838-1500. Municipal Securities Rulemaking Board (MSRB) MSRB’s Electronic Municipal Market Access (EMMA) Mutual Funds Breakpoint Information Mutual Funds Breakpoint Disclosure IEX Rulebook Northland Securities is a member of Investors Exchange (“IEX”). In connection with its membership, the Firm maintains electronic access to a current copy of the IEX rulebook and provides customers with such access upon request. Please contact your Northland Representative directly or the Northland Securities compliance department at 1-800-851-2920 or email c@northlandsecurities.com for a copy of the rulebook. DISCLOSURE OF PAYMENT FOR ORDER FLOW and ORDER ROUTING PRACTICES Payment for Order Flow In return for routing orders to a specific market center, Northland may receive what is known as “payment for order flow[1].” Currently, Northland receives liquidity rebates or credits for directing orders to specific venues for execution. These rebates reduce certain fees charged by those venues. Northland does not send orders to a specific venue in order to obtain a reduction of or credit against those fees. All customer orders subject to payment for order flow are sent to market centers that execute market and marketable limit orders at prices not inferior to the displayed National Best Bid or Offer (“NBBO”). Each market center provides the opportunity for execution of orders at prices better than the NBBO. Each order is exposed to exchanges and market centers for potential price improvement. A small percentage of NASDAQ orders are routed internally to our market maker. Northland executes these internal orders in a principal capacity, which may produce profit for Northland. The source and amount of such remuneration, if any, will be furnished to you upon written request. “any monetary payment, service, property, or other benefit that results in remuneration, compensation or consideration to a broker or dealer from any broker or dealer, national securities exchange, registered securities association or exchange member in return for the routing of customer orders by such broker or dealer to any broker or dealer, national securities exchange, registered securities association or exchange member for execution, including but not limited to: research, clearance, custody, products or services; reciprocal agreements for the provision of order flow; adjustment of a broker or dealer’s unfavorable trading errors; offers to participate as an underwriter in public offerings; stock loans or shared interest accrued thereon; discounts, rebates, or any other reductions of or credits against any fee to, or expense or other financial obligation of, the broker or dealer routing a customer order that exceeds that fee, expense or financial obligation.” Order Routing Practices The Securities & Exchange Commission (SEC) adopted Rule 606 (formerly SEC 11Ac1-6) of the Securities Exchange Act. Rule 606(a) which requires Northland Securities to comply with four primary disclosure elements for held, non-directed customer orders in Regulation NMS stocks: 1) to make publicly available quarterly reports that present a general overview of order routing practices for certain orders; 2) to disclose the nature of any relationship it has with venues that it routes client orders; 3) to furnish clients upon request the venues to which individual orders were sent for execution for the previous six months; and, 4) to provide an annual written notification to clients that this information is available upon request. Rule 606(b) requires Northland Securities to provide, upon request, specific disclosures regarding routing and execution for the preceding six months. SEC Rule 606(a) Northland Securities directs held orders for retail accounts in over-the-counter (OTC), listed stock, and options to our clearing firm, Pershing LLC (“Pershing”). In rare circumstances and depending on share quantity and additional factors, retail orders may be directed through our internal market maker for execution. Our clearing firm, Pershing LLC, may receive compensation or other consideration (“payment for order flow”) for directing such orders to particular broker-dealers or market centers for execution. Payments for order flow may consist of any monetary or non-monetary compensation, remuneration, or consideration to the clearing firm in return for routing customer orders to a particular market or dealer. Pershing may also receive credits, rebates, or discounts against execution fees. The source and nature of compensation received in connection with a trade will be furnished to you upon request to your Northland Securities Financial Representative. To view order execution details relating to Pershing’s payment for order flow practices, please see Pershing SEC Rule 606 disclosures at www.orderroutingdisclosure.com. Enter “Pershing LLC” in the field “Broker-Dealer’s Full Name.” To view Northland’s held order execution details relating payment for order flow, please click here. Enter “Northland Securities” in the field “Broker-Dealer’s Full Name.” SEC Rule 606(b) Northland Securities directs “not held” orders to various exchanges, market centers, or our internal market maker. Rule 606(b) requires Northland Securities to provide, upon request, specific disclosures regarding routing and execution, including the venue to which your orders were routed for execution for the preceding six months. To obtain a copy of these reports, please contact to your sales or trading representative. SEC Rule 605: Monthly Reporting on Quality of Executions As a market maker, Northland Securities is required to make publicly available reports that categorize order executions and provide statistical data about execution quality for orders covered under Rule 605. 2024 November: No Covered Orders 2024 October: No Covered Orders 2024 September: No Covered Orders 2024 August: No Covered Orders 2024 July: No Covered Orders 2024 June: No Covered Orders 2024 May: No Covered Orders 2024 April: No Covered Orders 2024 March: No Covered Orders 2024 February: No Covered Orders 2024 January: No Covered Orders 2023 December: No Covered Orders 2023 November: No Covered Orders 2023 October: No Covered Orders 2023 September: No Covered Orders 2023 August: No Covered Orders 2023 July: No Covered Orders 2023 June: No Covered Orders 2023 May: No Covered Orders 2023 April: No Covered Orders 2023 March: No Covered Orders 2023 February: No Covered Orders 2023 January: No Covered Orders 2022 January – December: No Covered Orders 2021 January – December: No Covered Orders Pershing Client Account Protection Information Visit Northland’s webpage with links to Pershing LLC Information Pershing Corestone Account Fee Disclosure Pershing Corestone Investor Fee Brochure Privacy Policies Northland is committed to the confidentiality and protection of personal non-public information obtained from clients. The privacy of your personal information and the way Northland treats that information is among Northland’s highest priorities. This is our opportunity to share with you the reasons why we need this information and our commitment to protecting the information you provide. Northland Privacy Policy BNY / Pershing Privacy Policy SEC Regulation BI Information and Disclosures The Securities and Exchange Commission (“SEC”) has adopted Regulation BI (“RegBI”), a new rule under the Securities Exchange Act of 1934 (“Exchange Act”) establishing a “best interest” standard of conduct for broker-dealers and Registered Investment Advisors (“RIAs”) and associated persons when making a recommendation of any securities transaction or investment strategy involving securities to a retail customer. The standard of conduct is to act in the best interest of the retail customer at the time a recommendation is made, without placing the financial or other interest of the broker-dealer, RIA, or associated person making the recommendation ahead of the interest of the retail customer. The SEC concurrently adopted a rule requiring each broker-dealer and RIA to provide its retail clients and file with the SEC a “Client Relationship Summary” (“Form CRS”) providing information about that broker-dealer or RIA and the way it conducts business. The RegBI Form CRS compliance and implementation date is June 30, 2020. INVESTOR INFORMATION Investor.gov Online Resource Site – SEC’s Office of Investor Education and Advocacy (OIEA) Investor.gov/CRS Site – SEC’s Form CRS Information FINRA Key Topic – SEC Regulation Best Interest SEC Regulation Best Interest, Form CRS, and Related Interpretations NORTHLAND DOCUMENTS Northland Form CRS Broker-Dealer ONLY (3/29/2024) Northland Form CRS Broker-Dealer & RIA DUAL (3/29/2024) Northland RegBI Disclosure Document (6-30-2020) SEC Registered Investment Advisor (RIA) Program Disclosures Northland Securities, Inc., Member of FINRA and SIPC, and Registered with SEC and MSRB. Northland conducts SEC Registered Investment Advisory business as Northland Asset Management. This RIA offers portfolio management services to institutions and individuals. As a Registered Investment Advisor (RIA) registered with the SEC, Northland Asset Management is required to provide details on our business through a pre-defined format laid out in the SEC’s Form ADV. This is Northland Asset Management ‘s Investment Advisory Brochure/Form ADV. Some Registered Representatives of Northland Securities may act as Investment Adviser Representatives (IARs) of Northland Asset Management. Registration as an Investment Adviser Representative does not imply a certain level of skill or training. A full text of Northland’s Code of Ethics is available upon request. Northland Securities, Inc. DBA Northland Asset Management – SEC Form ADV and Brochure Northland Research Services SEC Website Securities Investor Protection Corporation (SIPC) Northland Securities is a Member of FINRA and SIPC, and Registered with SEC and MSRB. SIPC is an important part of the overall system of investor protection in the United States. SIPC was created under the Securities Investor Protection Act as a non-profit membership corporation which protects against the loss of cash and securities – such as stocks and bonds – held by a customer at a financially-troubled SIPC-member brokerage firm. SIPC protection is limited and it does not protect against the decline in value of your securities. Investments in the stock market are subject to fluctuations in market value; SIPC was not created to protect against these risks. Securities Investor Protection Corporation (SIPC) Website Terms of Use Website Terms and Conditions —————————————————————————————————————————– If you have any questions or comments, or for additional information, please contact us at: Northland Securities Corporate Headquarters | Fifth Street Towers | 150 S. 5th St, Suite 3300 | Minneapolis, MN 55402 | Toll Free: 800.851.2920 | Phone: 612.851.5900 Any web links being provided are strictly as a courtesy to our clients. When you link to any of the sites provided here, you are leaving our site. Our company makes no representation as to the completeness or accuracy of information provided at these sites. Nor is the company liable for any direct or indirect technical or system issues or any consequences arising out of your access to or your use of third-party technologies, sites, information, and programs made available through this site. We do not necessarily endorse or accept any liability/responsibility for the content or use of these sites. Northland makes every effort to maintain current information, but please be aware information on this page may have changed.