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Nancy Barron & Associates, Inc.
150 Grand Boulevard
Lexington, KY 40507
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Local: 859-254-4010
 Toll Free: 800-489-4124
 Fax: 859-254-8497

Business Hours:
Monday through Friday
8am to 4pm

Regulatory Disclosures

Nancy Barron & Associate's Business Continuity Planning

Nancy Barron & Associates (NBA) has developed a Business Continuity Plan on how we will respond to events (ice storms, fire, terrorism, etc.) that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us - If after a significant business disruption you cannot contact us as you usually do at 859-254-4010, toll free at 800-489-4124, or at nbarron@nancybarron.com, you should first go to our web site at www.nancybarron.com and check for any current postings that would be found on the home page. If you cannot access us through any of those means, you should contact our clearing firm, National Financial Services, LLC (NFS), at 800-801-9942 for instructions on how it may provide prompt access to funds and securities, enter orders and process other trade-related, cash, and security transfer transactions for you. However, please note that if we are still in operation, calls to this line will be automatically directed to us at NBA.

Our Business Continuity Plan - We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.or at nbarron@nancybarron.com.

Nancy Barron & Associate's Privacy Policy

Effective January 2, 2002 in order to comply with the Privacy Provisions of the Gramm-Leach-Bailey Act, Nancy Barron & Associates, Inc. [hereinafter, “NBA”] has implemented the following NBA Privacy Policy to codify the protection of certain non-public information about their clients. This policy is intended to work in tandem with the privacy policy issued by NFSL.

The NBA Commitment
NBA is pledged to safeguard the use of client’s personal information that is collected in the course of doing business with those clients.

NBA does not sell any non-public information to anyone. Nor does NBA provide such information to any others except as may be necessary for discrete and proper business purposes or as mandated by authorized regulatory bodies.

NBA Information Collection
NBA may collect information from their clients from numerous sources, including but not limited to the following:

· Information clients may provide in establishing a new account with NBA including but not limited to their name, address, telephone number and social security numbers.

· Information clients may provide to NBA about their transactions outside NBA

· Information from consumer reporting agencies, public records and other data collection agencies.

NBA Information Use and Disclosure
NBA shall protect the security and confidentiality of all personal information and will make every effort to insure that such information is used solely for proper business proposes in connection with the management and servicing of the client’s account(s).

In situations where client information is shared [such as with correspondent clearing firms and mutual funds], NBA requires other parties to treat and maintain the privacy of that information to at least the same extent and with the same degree of diligence and careful attention that is required by NBA.

NBA does not disclose, and has no intention to disclose, any non-public personal information to non-affiliated third parties with respect to persons who are no longer our clients.

NBA Security Procedures
All NBA employees are advised about the NBA commitment to safeguard the confidentiality of our client’s non-public personal information. In addition, NBA maintains physical, procedural and electronic safeguards to protect this information from unauthorized access and dissemination.

Client Rights
NBA will send all clients a notice of our privacy policy annually for as long as a client maintains an ongoing business relationship with NBA. The practices and policies contained in this disclosure are subject to change, but NBA will communicate any material changes to their clients and provide a revised notice incorporating any material changes before NBA implements such changes.

Nancy Barron and Associates Order Routing Practices

SEC Rule 606 Quarterly Report for the Quarter Ending December 31, 2011

Securities Listed on New York Stock Exchange
Summary Statistics :
Non-directed orders as percentage of total customer orders 100.00%
Market orders as percentage of total non-directed orders 60.05%
Limit orders as percentage of total non-directed orders 39.95%
Other orders as percentage of total non-directed orders 0.00%

Venues Receiving Significant Percentage of Total Non-Directed Orders :
1. Knight Capital Markets, LLC 24.82%
2. National Financial Services LLC 20.33%
3. Citadel Securities LLC 19.15%
4. UBS Securities, LLC 13.24%
5. Direct Edge Exchange 6.86%
6. NYSE Arca 4.26%
7. Citigroup Global Markets, Inc. 3.78%
8. Two Sigma Securities, LLC 2.36%
9. BATS Exchange, Inc. 2.13%
10. AlterNet Securities Inc. 0.71%

Information Concerning Significant Venues :

1. Knight Capital Markets, LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 30.71%
Limit orders as percentage of total limit orders 15.98%
Other orders as percentage of total other orders 0.00%

2. National Financial Services LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 29.13%
Limit orders as percentage of total limit orders 7.10%
Other orders as percentage of total other orders 0.00%

3. Citadel Securities LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 13.39%
Limit orders as percentage of total limit orders 27.81%
Other orders as percentage of total other orders 0.00%

4. UBS Securities, LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 12.99%
Limit orders as percentage of total limit orders 13.61%
Other orders as percentage of total other orders 0.00%

5. Direct Edge Exchange
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 17.16%
Other orders as percentage of total other orders 0.00%

6. NYSE Arca
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 10.65%
Other orders as percentage of total other orders 0.00%

7. Citigroup Global Markets, Inc.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 5.91%
Limit orders as percentage of total limit orders 0.59%
Other orders as percentage of total other orders 0.00%

8. Two Sigma Securities, LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 3.15%
Limit orders as percentage of total limit orders 1.18%
Other orders as percentage of total other orders 0.00%

9. BATS Exchange, Inc.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 5.33%
Other orders as percentage of total other orders 0.00%

10. AlterNet Securities Inc.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 1.18%
Limit orders as percentage of total limit orders 0.00%
Other orders as percentage of total other orders 0.00%

Securities Listed on The Nasdaq Stock Market
Summary Statistics :
Non-directed orders as percentage of total customer orders 100.00%
Market orders as percentage of total non-directed orders 70.63%
Limit orders as percentage of total non-directed orders 29.38%
Other orders as percentage of total non-directed orders 0.00%

Venues Receiving Significant Percentage of Total Non-Directed Orders :

1. Knight Equity Markets, L.P. 23.13%
2. Citadel Securities LLC 21.25%
3. National Financial Services LLC 19.38%
4. UBS Securities, LLC 14.38%
5. Direct Edge Exchange 9.38%
6. NYSE Arca 4.38%
7. BATS Exchange, Inc. 3.13%
8. Goldman, Sachs & Co. 1.25%
9. AlterNet Securities Inc. 0.63%
10. Liquidnet 0.63%

Information Concerning Significant Venues :

1. Knight Equity Markets, L.P.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 27.43%
Limit orders as percentage of total limit orders 12.77%
Other orders as percentage of total other orders 0.00%

2. Citadel Securities LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 25.66%
Limit orders as percentage of total limit orders 10.64%
Other orders as percentage of total other orders 0.00%

3. National Financial Services LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 23.89%
Limit orders as percentage of total limit orders 8.51%
Other orders as percentage of total other orders 0.00%

4. UBS Securities, LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 16.81%
Limit orders as percentage of total limit orders 8.51%
Other orders as percentage of total other orders 0.00%

5. Direct Edge Exchange
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 31.91%
Other orders as percentage of total other orders 0.00%

6. NYSE Arca
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 14.89%
Other orders as percentage of total other orders 0.00%

7. BATS Exchange, Inc.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 10.64%
Other orders as percentage of total other orders 0.00%

8. Goldman, Sachs & Co.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 1.77%
Limit orders as percentage of total limit orders 0.00%
Other orders as percentage of total other orders 0.00%

9. AlterNet Securities Inc.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 2.13%
Other orders as percentage of total other orders 0.00%

10. Liquidnet
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.88%
Limit orders as percentage of total limit orders 0.00%
Other orders as percentage of total other orders 0.00%

Securities Listed on NYSE Amex or Regional Exchanges
Summary Statistics :
Non-directed orders as percentage of total customer orders 100.00%
Market orders as percentage of total non-directed orders 88.31%
Limit orders as percentage of total non-directed orders 11.69%
Other orders as percentage of total non-directed orders 0.00%

Venues Receiving Significant Percentage of Total Non-Directed Orders :
1. Knight Capital Markets, LLC 62.34%
2. National Financial Services LLC 23.38%
3. Citadel Securities LLC 9.09%
4. UBS Securities, LLC 2.60%
5. Direct Edge Exchange 1.30%
6. Citigroup Global Markets, Inc. 1.30%

Information Concerning Significant Venues :

1. Knight Capital Markets, LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 63.24%
Limit orders as percentage of total limit orders 55.56%
Other orders as percentage of total other orders 0.00%

2. National Financial Services LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 22.06%
Limit orders as percentage of total limit orders 33.33%
Other orders as percentage of total other orders 0.00%

3. Citadel Securities LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 10.29%
Limit orders as percentage of total limit orders 0.00%
Other orders as percentage of total other orders 0.00%

4. UBS Securities, LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 2.94%
Limit orders as percentage of total limit orders 0.00%
Other orders as percentage of total other orders 0.00%

5. Direct Edge Exchange
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 11.11%
Other orders as percentage of total other orders 0.00%

6. Citigroup Global Markets, Inc.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 1.47%
Limit orders as percentage of total limit orders 0.00%
Other orders as percentage of total other orders 0.00%

Exchange - Listed Options
Summary Statistics :
Non-directed orders as percentage of total customer orders 100.00%
Market orders as percentage of total non-directed orders 32.17%
Limit orders as percentage of total non-directed orders 67.83%
Other orders as percentage of total non-directed orders 0.00%

Venues Receiving Significant Percentage of Total Non-Directed Orders :
1. The Chicago Board Options Stock Exchange 48.25%
2. NASDAQ OMX PHLX 16.08%
3. NYSE Arca Options 9.79%
4. The Boston Option Exchange 9.09%
5. NYSE Amex Options 7.69%
6. BATS Options Exchange, Inc. 4.90%
7. C2 Options Exchange 1.40%
8. The International Securities Exchange 1.40%
9. Nasdaq Execution Services, LLC 1.40%

Information Concerning Significant Venues :

1. The Chicago Board Options Stock Exchange
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 52.17%
Limit orders as percentage of total limit orders 46.39%
Other orders as percentage of total other orders 0.00%

2. NASDAQ OMX PHLX
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 8.70%
Limit orders as percentage of total limit orders 19.59%
Other orders as percentage of total other orders 0.00%

3. NYSE Arca Options
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 14.43%
Other orders as percentage of total other orders 0.00%

4. The Boston Option Exchange
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 23.91%
Limit orders as percentage of total limit orders 2.06%
Other orders as percentage of total other orders 0.00%

5. NYSE Amex Options
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 10.87%
Limit orders as percentage of total limit orders 6.19%
Other orders as percentage of total other orders 0.00%

6. BATS Options Exchange, Inc.
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 7.22%
Other orders as percentage of total other orders 0.00%

7. C2 Options Exchange
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 2.06%
Other orders as percentage of total other orders 0.00%

8. The International Securities Exchange
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 4.35%
Limit orders as percentage of total limit orders 0.00%
Other orders as percentage of total other orders 0.00%

9. Nasdaq Execution Services, LLC
Types of Orders Routed to Venue :
Market orders as percentage of total market orders 0.00%
Limit orders as percentage of total limit orders 2.06%
Other orders as percentage of total other orders 0.00%