Best Execution Analysis

J.P. Turner provides clients products to assist them in complying with the Securities and Exchange Commission (SEC) Rule 605 and SEC Rule 606 through SunGard Trading Systems.

Pursuant to SEC Rule 606, Penson Financial Services, Inc. is required to make publicly available a quarterly report with regard to its routing of non-directed orders. For the purpose of this Rule, Penson Financial Services, Inc has entered into an agreement with Quantum5 Market Surveillance (a Division of S3 Matching Technologies ) to disclose all required information pertaining to this rule. This information can be accessed on the internet at: ftp://public.s3.com/11ac1-6/pfsi, or a written copy will be furnished at no cost upon request via telephone to 214-765-1009 or email to cs@penson.com. Note: Section 4 Exchange Listed Options is the only portion of this document relevant to J.P. Turner and Company clients for Equities 605 / 606 reporting please refer to the Sungard link above and referenced for your convenience again here http://www.brasscompliance.com/.

This product is available to all clients. SEC rules mandate that firms publish, on a public Web site, specific data that relate to order execution (Rule 605) and order routing (Rule 606) practices.