SEC Disclosure



	11Ac1-6 (3rd Qtr 2001) 11Ac1-6 (4th Qtr 2001) 11Ac1-6 (1st Qtr 2002) 11Ac1-6 (2nd Qtr 2002) 11Ac1-6 (3rd Qtr 2002) 11Ac1-6 (4th Qtr 2002) 11Ac1-6 (1st Qtr 2003) 11Ac1-6 (2nd Qtr 2003) 11Ac1-6 (3rd Qtr 2003) 11Ac1-6 (4th Qtr 2003) 11Ac1-6 (1st Qtr 2004) 11Ac1-6 (2nd Qtr 2004) 11Ac1-6 (3rd Qtr 2004) 11Ac1-6 (4th Qtr 2004) 11Ac1-6 (1st Qtr 2005) 11Ac1-6 (2nd Qtr 2005) 11Ac1-6 (3rd Qtr 2005) 11Ac1-6 (4th Qtr 2005) 11Ac1-6 (1st Qtr 2006) 11Ac1-6 (2nd Qtr 2006) 11Ac1-6 (3rd Qtr 2006) 11Ac1-6 (4th Qtr 2006) 11Ac1-6 (1st Qtr 2007) 11Ac1-6 (2nd Qtr 2007) 11Ac1-6 (3rd Qtr 2007) 11Ac1-6 (4th Qtr 2007) 11Ac1-6 (1st Qtr 2008) 11Ac1-6 (2nd Qtr 2008) 11Ac1-6 (3rd Qtr 2008) Disclosure Information: Vanguard Capital 4275 Executive Square, Suite 230 La Jolla, CA 92037 SEC-Required Report on Routing of Customer Orders Vanguard Capital has prepared this report pursuant to a U.S. Securities and Exchange Commission rule requiring all brokerage firms to make publicly available quarterly reports on their order routing practices. The report provides information on the routing of “non-directed orders” - any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, Vanguard Capital has selected the execution venue on behalf of its customers. The report is divided into four sections: one for securities listed on the New York Stock Exchange, one for securities listed on the Nasdaq Stock Market, one for securities listed on the American Stock Exchange or regional exchanges, and one for exchange-listed options. For each section, this report identifies the venues most often selected by Vanguard Capital, sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of Vanguard Capital’s relationship with the venues. Vanguard Capital has provided data concerning the routing of order flow ("the Data") through this website. Although Vanguard Capital has used commercially reasonable efforts to provide accurate Data, the Data is believed to be reliable but no representation is made as to accuracy or completeness. Disclosure Details: Securities Listed on the New York Stock Exchange In certain transactions, Vanguard Capital receives remuneration for directing orders to various market centers for execution. The source and the amount of compensation received in connection with a transaction and any additional information concerning order flow payment will be furnished upon request. Vanguard Capital generally routes trades through another broker-dealer in return for payment for order flow. Such payments are in the form of cash rebates paid by the broker-dealer. The broker-dealer affords all such forwarded orders opportunities for price improvement over the National Best Bid or Offer. Theses opportunities include crossing market orders and limit orders with unexecuted better-priced limit orders housed on the broker’s open order book. Vanguard Capital monitors all trade executions internally to assure that clients are receiving best execution, including trades routed to such other broker-dealer for payment for order flow. Vanguard Capital does not include order routing inducements in its analysis of market quality. Payment for order flow has no impact on the execution prices that customers receive. Securities Listed on the Nasdaq Stock Market In certain transactions, Vanguard Capital receives remuneration for directing orders to various market centers for execution. The source and the amount of compensation received in connection with a transaction and any additional information concerning order flow payment will be furnished upon request. Vanguard Capital generally routes trades through another broker-dealer in return for payment for order flow. Such payments are in the form of cash rebates paid by the broker-dealer. The broker-dealer affords all such forwarded orders opportunities for price improvement over the National Best Bid or Offer. Theses opportunities include crossing market orders and limit orders with unexecuted better-priced limit orders housed on the broker’s open order book. Vanguard Capital monitors all trade executions internally to assure that clients are receiving best execution, including trades routed to such other broker-dealer for payment for order flow. Vanguard Capital does not include order routing inducements in its analysis of market quality. Payment for order flow has no impact on the execution prices that customers receive. Securities Listed on the American Stock Exchange In certain transactions, Vanguard Capital receives remuneration for directing orders to various market centers for execution. The source and the amount of compensation received in connection with a transaction and any additional information concerning order flow payment will be furnished upon request. Vanguard Capital generally routes trades through another broker-dealer in return for payment for order flow. Such payments are in the form of cash rebates paid by the broker-dealer. The broker-dealer affords all such forwarded orders opportunities for price improvement over the National Best Bid or Offer. Theses opportunities include crossing market orders and limit orders with unexecuted better-priced limit orders housed on the broker’s open order book. Vanguard Capital monitors all trade executions internally to assure that clients are receiving best execution, including trades routed to such other broker-dealer for payment for order flow. Vanguard Capital does not include order routing inducements in its analysis of market quality. Payment for order flow has no impact on the execution prices that customers receive. . Exchange-Listed Options Material Aspects of Relationship with Venue: Pershing Vanguard Capital directs its order flow to Pershing for execution. Vanguard Capital receives NO payments for directing order flow to Pershing. Vanguard Capital regularly reviews reports for quality of execution purposes.

	Vanguard Capital is not affiliated with the Vanguard Group of mutual funds.