In compliance with SEC Regulation SP, we notify you annually of our policies and procedures with regards to how we handle clients’ records. Gagnon Securities has a long standing policy committed to protecting our clients’ confidentiality and the security of all information obtained from our clients. If you have any questions or concerns regarding these procedures discussed below, please do not hesitate to call me directly.

Prior to opening an account with us, we obtain directly from you financial and personal information. This information is used by your broker and our management team to evaluate suitability for our investment approach, as well as to determine how together we can meet your individual investment goals. Periodically we will ask that you furnish us with updated information.

All persons employed with Gagnon Securities have access to this information for administrative purposes. All client files and records are kept within a secured area of the office clearly marked authorized personnel only. Our employees are required to protect our clients’ confidentiality and access information only when appropriate to do so. Violators of our policies would be subject to disciplinary action and/or legal action, per our confidentiality agreement that all employees are required to sign.

We clear all of our accounts through National Financial Services LLC, a Fidelity Clearing & Custody Solutions® on a fully disclosed basis. Therefore, we forward all information and documentation pertaining to your account to them at the time your account is opened. Moreover, National Financial Services LLC maintains this information and records all account activity. National Financial Services LLC has its own privacy policy that it will forward to you under separate cover.

Gagnon Securities shares office space with other unaffiliated companies and individuals. Unaffiliated persons have an office distinctly separate from Gagnon Securities and have access only to “common areas” within our office. Unaffiliated persons or visitors to our floor are restricted from entering areas in which your personal information is kept.

It is our policy not to share or disclose any information to any persons or business entity except as permitted by law or specifically directed to do so by our clients.

I hope you have found this brief discussion informative and if you have any questions please contact me directly at212-554-5060. Thank you for your consideration.


Lisa Ferrante
Chief Compliance Officer