Order Routing Disclosure

Gabelli & Company, Inc. has prepared this report under Securities and Exchange Commission Rule 606. The Rule requires that we disclose how we route orders for customers who have not specified where they want their orders executed. For these orders-called "non-directed orders," we decide where to send them for execution.

Gabelli & Company, Inc. has attempted to prepare these statistics in compliance with SEC Rule 606. However, these statistics have not been audited and may contain errors. Gabelli & Company, Inc. does not represent, warrant, or guarantee that the statistics are accurate. Gabelli & Company, Inc. disclaims liability for any direct, indirect, punitive, special, consequential, or incidental damages related to the statistics or the use of such. The information provided in the reports may be impacted by market data system outages or errors, both internal and external, and it is dependent upon the integrity and accuracy of data provided by outside sources. Certain assumptions have been made in preparing the statistics, and changes to the assumptions may have a material impact on results. The statistics do not endorse or recommend any particular security or market participant.

SEC Rule 606 also requires disclosure of any relationship we have with the venues to which we send orders. This disclosure is intended to alert customers to potential conflicts of interest that may influence how a broker-dealer routes orders. Gabelli & Company, Inc. has no payment for order flow arrangements. Gabelli & Company, Inc. routes non-directed orders to the venue that it believes offers the best available execution.

Customers wanting details about the routing of their orders should write to Josephine LaFauci, Chief Compliance Officer of Gabelli & Company, Inc., at One Corporate Center, Rye, NY 10580-1422.