As a dual registrant with a broker-dealer and an investment adviser, our registered personnel may act in either capacity. Although some clients hire us in only one of these capacities, we have many clients who hire us in both. If you have hired or plan to hire us in one capacity or the other, then we will be acting only in that capacity. If you have hired or plan to hire us in both capacities and our investment adviser has or will have discretion over your portfolio, then we will generally be acting in the investment adviser capacity when our personnel communicate with you, discuss investments with you and make investment recommendations to you. This will be the case unless we specifically state otherwise. Additionally, should our clients ever be unsure in which capacity we are acting during a communication, we request that they make this known to us so that we may clarify our capacity with them.

When acting as investment adviser, in other fiduciary capacities or as your broker-dealer, we may hold or invest your assets in mutual funds, money market funds, annuities or other pooled investments ("Funds"). Such Funds are generally bought and sold at net asset value, resulting in no direct sales charge to the client account. The Fund management companies and their affiliates charge various commissions or management fees for their services, as described in their prospectuses. These commissions and fees are separate from, and in addition to, the fees that you pay to us. For clients who engage our affiliated broker-dealer, Kahn Brothers LLC, a portion of the commissions or fees charged by Fund management companies or their affiliates for investments in certain share classes may be paid to Kahn Brothers LLC or to third-party service providers for administrative services. Such payments are governed by Rule 12b-1 of the Investment Company Act of 1940, as amended. The fees (known as "12b-1 fees") are generally less than 1.0% of the average annual share value of Fund shares. When 12b-1 fees arise from fund assets, or assets held in the subaccounts of annuities, life insurance policies or other similar products, they are retained or credited to Kahn Brothers LLC or our third-party service providers, for our or their own account(s). For clients engaging Kahn Brothers LLC, we invest your assets in Funds carried on Pershing's platform. Currently, each Fund carried on Pershing's platform in which we may invest your assets has only a single share class available on the platform. In the event that we invest your assets in Funds for which there are multiple available share classes, we have a financial incentive to recommend or select those share classes that result in higher compensation to us through the payment of 12b-1 fees when you may otherwise be eligible for a lower fee-paying share class in the same Fund. This creates a conflict of interest between us, the investment manager whose affiliated broker-dealer may receive fees connected to a particular share class, and you, the client, for whom the recommendation or selection is being made. To mitigate such conflict of interest, we will take measures to ensure the appropriateness of the Fund share class selection, based upon your particular investment objectives and any other appropriate considerations relevant to such share class selection. In taking such measures, we will seek to place your funds in the share class with lower fees, absent extenuating factors that make a higher fee share class more appropriate for you.

Kahn Brothers LLC may solicit its clients to enter into discretionary advisory relationships with its affiliated investment adviser, Kahn Brothers Advisors LLC. Such a discretionary relationship, which is different from a non-discretionary brokerage relationship, would result in additional revenue to the Firm if you continue to employ our broker-dealer for securities transactions. Our principals are also principals of affiliated investment firms that act as investment adviser to limited partnerships. Although not common, our principals may solicit you to make investments in these partnerships. These partnerships employ largely the same investment strategies as our other registered investment adviser and our broker-dealer. If you invest in these limited partnerships, this will likely result in additional revenue to the Firm. There is a conflict of interest in that your cost structure for an investment in these vehicles would be dissimilar to the cost structure of your client account with us. In some cases, depending on the nature of your relationship with us, and in some billing periods, the costs may be higher; in others, they may be lower. We address this conflict by fully describing to the solicited client the two cost structures, their differences and the conflicts of interest that would be associated with them. More on this topic and how it is addressed can be found in Form ADV Part 2A of Kahn Brothers Advisors LLC at

Our Firm employs a modified value investing style that seeks to protect against permanent loss of capital while achieving long-term total returns exceeding a reasonable benchmark. We manage and recommend investments primarily in publicly-traded equities but may also transact other securities, such as (but not limited to) American Depository Receipts, investment fund shares, warrants, rights and fixed income and derivative securities. We may engage in long or short transactions, although short selling is generally not employed. We focus on long-term performance over many years. The duration of a typical investment is three to five years or longer.

Our investment decisions and recommendations are generally based on a modified value investing strategy which relies primarily on a bottoms-up process of fundamental analysis of securities. We seek stocks whose prices we believe to be cheap relative to "intrinsic value." Our team seeks value opportunities wherever they may find them, in companies large and small and across industries. However, we tend to focus on securities trading in U.S. markets. Our investment process may often be characterized as "contrarian." Our managers and representatives may look for out-of-favor stocks or stocks in undervalued economic sectors, rather than seeking out popular industries or industry leaders of the day. We may also invest in "special situations" in which the potential upside of the investment is heavily dependent on a material corporate action. We may purchase stock in micro, small or medium capitalization companies or in companies with large amounts of closely-held shares. Such securities may be traded more infrequently, in smaller quantities, or in the less liquid over-the-counter market. As with all investments, you should be familiar with the characteristics and trading liquidity of these securities if they are ever recommended or purchased. You will find information on the risks of small and illiquid securities below.

All investments in securities, including those transacted by us, involve a risk of realized loss of capital that clients should be prepared to bear. We strive to mitigate this risk by refraining from the purchase of securities that we deem to be overpriced and by employing a long-term investment strategy that can help to safeguard against permanent loss in periods of short-term volatility. However, there is no guarantee that our strategy or our analysis of an investment will be correct, and realized losses may occur.

In general, investing is subject to many risk factors, some of which are within our control and some of which are not. Factors out of our control include varied economic, political and social events that may negatively affect investments. Increased volatility of the markets may lead to adverse investment performance for periods of time. If investors are forced to or elect to liquidate investments when volatility has driven a stock's price below cost, this will result in a realized loss.

Some types of investments that we generally do not recommend have inherent risks particular to them as described here. Short sales, although generally not used, carry a risk of loss that is theoretically unlimited. Potential monetary losses on short sales have no upward bounds. Fixed-income investments carry varied risks, including interest rate risk, credit risk and reinvestment risk, among others types of risk. Interest-rate sensitive securities, including preferred equity securities, have interest-rate risk associated with them. Investments in options contracts carry various risks including but not limited to, for long positions, the potential for 100% loss of premium; for uncovered short calls, a potential for loss that is theoretically unlimited; and, for options in general, a potential for losses that are significantly levered relative to the amount of one's original investment.

We employ a modified value investing strategy. Although value investing seeks to mitigate risk by avoiding the purchase of what we believe to be aggressively valued securities, you should be aware that there are risks particular to this strategy. It is possible that the market may undervalue an investment for an indefinite or unacceptably long period of time. This can negatively impact the investment's desired return or lead to losses. Additionally, when investing in "fallen angels" or out-of-favor companies and industries, there is a risk that these companies or industries may fail to regain favor and that this will negatively impact returns or lead to losses. There is a risk that investments in "special situations" will not produce the desired return or will lead to losses if the anticipated corporate action does not materialize, takes a different form than anticipated, or materializes after an unacceptably long period of time. All of these risks may be greater for investments in small or illiquid companies. Our modified value investing approach is just one particular investment style. There is a broad universe of different styles, each with its own advantages and disadvantages. There is a wide array of opinions on the strengths and weaknesses of each style. You should be aware that discretionary or solicited investments with us will generally be made according to our modified value investing style—other styles will generally not be employed. Therefore, discretionary or solicited investments with us will generally not be diversified by investment methodology. We invest most often in the public equities markets. Accordingly, discretionary or solicited investments with us will most likely not be diversified by asset class. However, you may always diversify your investments with us by style or asset class on a non-discretionary or unsolicited basis. There will be times when the market becomes overpriced as a whole, and, during these times, underpriced and attractive investments may become harder to identify. In such markets, we may prefer or recommend you hold large amounts of cash and equivalents in your account rather than investing in securities that we believe to be risky due to overvaluation. You should understand that, during these periods, your cash and equivalents may produce little to no return depending on prevailing interest and inflation rates. As with any long-term investment, there is the potential for your holdings to incur unrealized losses for periods of time and for your portfolios to underperform benchmark indices for periods of time or indefinitely. There will be times, particularly early in an investment, when a security's price may be low enough to be unattractive to sell. There may also be times when the price will be low enough to produce a realized loss if sold. Absent highly unusual circumstances, we will not recommend exiting investments during these periods. Accordingly, you should be prepared to hold your investments during these periods and, in some cases, at our recommendation, to increase your holdings at the reduced prices that have presented themselves. If, against our advice or recommendation, you instruct us not to increase your position when a security's price has decreased, you may realize a return below expectations. If you choose to exit an investment during a period of underperformance, you may incur a realized loss or a return below expectations that you should be prepared to sustain.

The increased use of technologies to conduct business increases operational, information security and related risks. Cyber incidents can result from deliberate attacks or unintentional events and include, but are not limited to, gaining unauthorized access to digital systems for the purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches by issuers of securities or the exchanges on which they are traded have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, interference with or impediments to trading, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, and reimbursement or other compensation costs.

The ongoing outbreak of a novel and highly contagious form of coronavirus ("COVID-19"), which the World Health Organization declared a global pandemic on March 11, 2020, has caused a worldwide public health emergency with a substantial number of hospitalizations and deaths and has significantly adversely impacted global commercial activity and contributed to both volatility and material declines in commodity, equity and debt markets. The effects of the COVID-19 pandemic may pose unanticipated risks for the Firm's ability to achieve its investment objectives, which could result in losses to the Firm's clients.

In response to the spread of COVID-19, many businesses, including the Firm, have encouraged or mandated that their personnel work from home in an effort to help slow the spread of the coronavirus pandemic. To the extent personnel, as a result of working remotely, rely more heavily on external sources for information and technology systems for their business-related communications and information sharing, that business may be more vulnerable to cybersecurity incidents and cyberattacks. The Firm has adopted and implemented policies and procedures to mitigate its cybersecurity risk and maintains the ability to operate remotely.

As a matter of policy and practice, the Firm generally does not aggregate client trades, and, therefore, we generally implement client transactions separately for each account. Consequently, trades in a particular security for a particular client may be executed before or after trades in that security for other clients, at a different price and/or commission rate. The practice of implementing client transactions separately for each account (as opposed to aggregating client trades in identical securities) does not impact the commission rates you would otherwise pay to Kahn Brothers LLC. It is our policy to allocate purchases and sales of securities fairly among our advisory clients and to always instruct our broker-dealer to give our clients priority in execution over us, our affiliated businesses, its related persons, and entities in which we, our affiliated businesses or related persons have a financial interest. When we receive or seek to process multiple orders in the same security, on the same side and in close temporal proximity to one another, we endeavor to review and process the accounts in a different sequence each time in order to mitigate preference to one particular account. Our officers regularly review all trading activity in advisory, employee and related party accounts to ensure that these policies are honored.

Before entering into an investment advisory or brokerage relationship with us, you are advised that we and our employees own or may own directly or indirectly the same securities that we will recommend and transacted for you. If we or our principals or employees have a material financial interest in a company that we are currently recommending, this interest will be disclosed to you before recommending that company to you. Generally, an investment adviser or broker-dealer may be biased towards recommending such investments regardless of their merits or suitability to the client. However, we believe there are significant benefits to investing with a Firm that "eats its own cooking." The Firm's related entities may take action with respect to a security that is different from the action it has recommended to clients. For example, the Firm's related entities may retain a position on a security that it has recommended clients sell or vice versa or the Firm's related entities may sell part of a position while recommending to clients that they sell all of the position or vice versa. These instances may occur as a result of the Firm's related entities' individual financial needs and contexts, which will be different to varying degrees from those of the Firm's clients, even if they share a common investment philosophy. For more information on these subjects, please refer to the current ADV Part 2A Brochure of Kahn Brothers Advisors LLC at

Orders are processed when received. In any given trading session, active client orders will have priority over orders for our firms, employees and affiliated persons and entities. When our adviser seek to make multiple similar orders in the same security in close temporal proximity to one another, we endeavor to review and process the accounts in a different sequence in order to mitigate preference to one particular account.

Brokerage commissions are typically negotiated at the inception of our relationship and, for mutual clients of our investment adviser and broker-dealer, formalized in those clients' investment advisory agreements. When seeking to engage our broker-dealer, you will receive information in your introductory materials on the relationship between the two firms (should you wish to engage both), as well as a representative illustration of Kahn Brothers LLC's commission arrangements, which is also available anytime upon request. You are advised that our longer commission schedule is also available upon request. Clients and prospective clients of Kahn Brothers Advisers LLC are under no obligation to utilize the services of its affiliated broker dealer and may elect to use a third-party unaffiliated broker dealer and still retain advisory services from the investment adviser. You are advised that using a broker-dealer that is affiliated with your own investment adviser can create incentives for that investment adviser to generate unnecessary trading activity in your account. The Firm monitors all trading activity to mitigate this conflict of interest.

A statement of financial condition is available upon request. Associated persons of our broker-dealer and investment adviser may have additional conflicts of interest beyond those disclosed to you in the materials you have received and been referenced to, and these conflicts will be disclosed to you when they arise, where appropriate. For more information on the scope and nature of our services, the fees and charges associated with our services, the risks of investing with us and additional disclosures from our investment adviser which may pertain to you, please refer to the current ADV Part 2A Brochure of Kahn Brothers Advisors LLC at