Disclosures

General Disclosures

The U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) require member firms to disclose to their customers when opening an account and at least once a year after that, their policies and procedures regarding customer identification, business continuity, trade routing, and investor protection.
Sumridge Partners, LLC ("Firm") has created and implemented its own policies and procedures in an effort to mitigate the effects related to unforeseen business interruptions, to supply the necessary routing information about specific orders, and to provide investor protection.
Enclosed you will find our disclosure statements in those areas.

The Securities and Exchange Commission ("SEC") requires all registered broker-dealers to disclose their policies regarding receipt of "payment for order flow". The Commission defines "payment for order flow" as "any monetary payments, services, property, or other benefits that result 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 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, effort to participate as 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 other financial obligation".
SumRidge Partners LLC may receive from time to time remuneration in the form of rebates for providing liquidity to Electronic Communications Networks ("ECN's"). The rebates are used to offset the cost of execution charged to SumRidge by the ECN. Any additional information concerning order flow payment will be disclosed upon written request.

Business Continuity Planning

SumRidge Partners, LLC has developed a Business Continuity Plan on how we will respond to events 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 201-898-2525/Trading@Sumridge.com, you should go to our website at Sumridge.com. If you cannot access us through either of those means, you should contact our clearing firm, Pershing, LLC at 201-413-3333 for instructions. For more information on Pershing’s business continuity plan, visit https://www.pershing.com/content/dam/pershing/documents/pdfs/disclosures/per-business-continuity.pdf.

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 backup 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.

For more information – If you have questions about our business continuity planning, you can contact us at 201-898-2525 or Compliance@sumridge.com.

Privacy Notice

The following information describes how SumRidge Partners, LLC ("SumRidge") handles your nonpublic personal information. SumRidge may 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 SumRidge or other third-parties, including affiliated entities, such as that pertaining to your account balance, account transactions, payment history and parties to transactions;

SumRidge does not disclose nonpublic personal information about you to anyone, except to affiliated entities or as permitted by law. Accordingly, SumRidge restricts disclosure of nonpublic personal information about you to:

1.SumRidge employees who need to know that information to provide you products or services,

2.Non-affiliated third-parties as necessary to process your transactions, service your account or otherwise as permitted by law, and

3.Affiliated entities as necessary to process your transactions and service your account, or for such affiliated entities to use your information for everyday business purposes and to market to you.

If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice. SumRidge does not sell personal nonpublic information about current or former customers to any third-parties or share that information with unaffiliated third-parties for marketing purposes.

Please contact your Sales Representative if you would like to opt-out of sharing your information with affiliated entities for marketing purposes.

FINRA Public Disclosure Program

FINRA Rule 2267 requires that we notify you, in writing, about the availability of an investor brochure that includes information describing the FINRA public disclosure program, BrokerCheck. To obtain a brochure or more information about BrokerCheck, please call the FINRA BrokerCheck Hotline at (800) 299-9999. To get information on a firm or broker, go to www.finra.org, click on FINRA BrokerCheck, and follow the instructions.

Municipal Securities Rulemaking Board (MSRB) Rule G-10 Investor Education and Protection Annual Disclosure

SumRidge Partners, LLC is registered with the U.S. Securities and Exchange Commission (SEC) and the MSRB. The website for the SEC is www.sec.gov and the website for the MSRB is www.msrb.org.
Note that in addition to having educational material about the municipal securities market, the MSRB website has an investor brochure that describes the protections that may be provided by the MSRB rules and how to file a complaint against the Firm or its representatives with an appropriate regulatory agency.
The MSRB Municipal Securities Investor Brochure can be found at here.

Complaints

Please direct all complaints to the SumRidge Partners, LLC's Compliance Department. The Department can be reached at (201) 898-2521 or 111 Town Square Place, Suite 320, Jersey City, New Jersey, 07310.

SIPC Protection

SumRidge Partners, LLC is a member of the Securities Investor Protection Corporation ("SIPC"). For more details on SIPC, or to request a SIPC brochure, visit www.sipc.org or call 1-202-371-8300.

Important Information About Account Opening Procedures

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 or entity with an account relationship.

For corporations, partnerships, trusts or other entities opening accounts with SumRidge Partners, LLC, you will be asked to provide (1) name, (2) street address, (3) a US taxpayer ID (or government issued documents for foreign entities), and (4) any other information or documents that may be necessary to verify identity.

Extended Hours Trading Risk Disclosures

You should consider the following points before engaging in extended hours trading. “Extended hours trading” means trading outside of "regular trading hours". "Regular trading hours" generally means the time between 8:00 a.m. and 5:00 p.m. Eastern Standard Time.

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 trading 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 trading hours. As a result, your order may only be partially executed, or not at all, or you may receive an inferior price when engaging in extended hours trading than you would during regular trading 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 trading hours, or upon the opening the next morning. As a result, you may receive an inferior price when engaging in extended hours trading than you would during regular trading 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 trading 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 New Announcements. Normally, issuers make news announcements that may affect the price of their securities after regular trading hours. Similarly, important financial information is frequently announced outside of regular trading 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.

For additional information, please refer to FINRA Rule 2265 and FINRA Notice to Members 00-07.

Statements; Electronic Delivery; Notices

SumRidge Partners, LLC may send you Account Notices in either electronic or paper format. You consent to and agree to accept electronic delivery of Account Notices to the extent available, other than those you may have specifically requested be delivered to you in paper form. “Account Notices” include statements, trade confirmations, notices, disclosures, regulatory communications, prospectuses, proxy solutions and privacy notices, and other information, documents, data, and other records regarding your account. Your consent to electronic delivery of Account Notices means that you accept electronic delivery in lieu of mailed paper notices, which will remain effective until you revoke such consent. So long as SumRidge Partners, LLC sends communications to you at the physical or electronic address of record given by you on the date of application, or to any other address given to us by you, the communications are legally presumed to have been delivered, whether you actually received them or not.

For Australian Clients Only

Under the Australian licensing requirements, the provision of financial services to Australian entities generally requires a financial service provider to hold an Australian Financial Services License, unless Class Order relief is granted by the Australian Securities and Investments Commission (ASIC).If you are domiciled in Australia, please be advised that SumRidge Partners, LLC is exempt from the requirement to hold an Australian financial services license under the Corporations Act 2001 of Australia (the Act) in respect of the financial services being provided to you. Please note that SumRidge Partners, LLC is primarily regulated by the U.S. Securities and Exchange Commission and the Financial Regulatory Authority under the laws of the United States of America, which differ to Australian laws.

SumRidge Partner, LLC understands that you are a wholesale client within the meaning of section 761G of the Act (Wholesale Client). SumRidge Partners, LLC may only continue to provide you with financial services pursuant to the Class Order [CO 03/1100] while you remain a Wholesale Client. Please inform you usual contact at SumRidge Partners, LLC if you are not a Wholesale Client now or if you cease to be a Wholesale Client at any time in the future.

Notice to Canadian Clients – Reliance on International Dealer Exemption

SumRidge Partners, LLC (the Firm) is relying on the international dealer exemption pursuant to section 8.18 of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations in Québec.

Further to relying on such exemption, we are required to advise you of the following:

The Firm is not registered in the above noted jurisdiction to act as a dealer.
The head office of the Firm is 111 Town Square Place, Jersey City, New Jersey, 07310, USA.
All or substantially all of the Firm’s assets may be situated outside of Canada.
There may be difficulty enforcing legal rights against the Firm because of the above.
The name and address of the Firm’s agent for service of process in the jurisdiction is as follows:

Québec

Fasken Martineau DuMoulin LLP
3500-800, rue du Square-Victoria
Montréal, Québec H3C 0B4

Contact:Julie Delisle, Senior Director, Commercial & Related Services
Tel: 1-514-397-7423
Email: jdelisle@fasken.com

If you have any questions about the foregoing, please do not hesitate to contact your relationship manager.

Notice to Municipal Entity Clients - Disclosures Regarding Your Account(s) with SumRidge Partners, LLC

We are providing you with certain disclosures and disclaimers in connection with Section 15B of the Securities Exchange Act of 1934 (the “Act”) (SEC Rule 15Ba1-1 et seq.) (the “Municipal Advisor Rule” or the “Rule”), regarding your accounts (the “Account(s)”) with SumRidge Partners, LLC.

Please be advised that:

SumRidge Partners, LLC is not recommending and will not recommend an action to you;
SumRidge Partners, LLC is not providing and will not provide “advice” to you as defined in the Rule, and any information or communication from SumRidge Partners, LLC in respect of the relevant Account(s) is not intended to be and should not be construed as “advice” as defined in the Rule; and
SumRidge Partners, LLC is not acting as an advisor to you and does not owe you a fiduciary duty pursuant to Section 15B of the Act with respect to any information or material provided by SumRidge Partners, LLC in connection with trading, investing or other activity in the Account(s).

You should discuss any information or material provided to you by SumRidge Partners, LLC in connection with trading, investing or other activity in the Account(s) with any and all of your internal or external advisors and experts that you deem appropriate before acting on any such information or material.

You may contact your Sales Representative if you have any questions.

Privacy Notice – California Residents

By engaging in and continuing to do business with SumRidge, you consent to sharing of your account and transaction information with its affiliates, including Raymond James & Associates, Inc., for everyday business purposes or to market to you. SumRidge may utilize certain order and trade information to provide market color or trend analyses to affiliated sales and trading desks to enhance the quality of execution or other services offered to customers. These information-sharing practices do not alter SumRidge’s policy to achieve best execution and fair pricing, taking into account, among other factors, price, transaction cost, volatility, market depth, quality of service, speed, and efficiency. You may contact your Sales Representative and withdraw your consent or any previously given consent at any time.