Form Sec 1707 - Uniform Application For Investment Adviser Registration - Securities And Exchange Commission Page 11

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Your Name _______________________________ CRD Number _______________
FORM ADV
Part 1A
Date _____________________________________ SEC 801-Number ____________
Page 11 of 16
Proprietary Interest in Client Transactions
A. Do you or any related person:
Yes
No
(1) buy securities for yourself from advisory clients, or sell securities you own to
advisory clients (principal transactions)?
(2) buy or sell for yourself securities (other than shares of mutual funds) that you
also recommend to advisory clients?
(3) recommend securities (or other investment products) to advisory clients in
which you or any related person has some other proprietary (ownership)
interest (other than those mentioned in Items 8.A(1) or (2))?
Sales Interest in Client Transactions
B. Do you or any related person:
Yes
No
(1) as a broker-dealer or registered representative of a broker-dealer, execute
securities trades for brokerage customers in which advisory client securities
are sold to or bought from the brokerage customer (agency cross transactions)?
(2) recommend purchase of securities to advisory clients for which you or any related
person serves as underwriter, general or managing partner, or purchaser
representative?
(3) recommend purchase or sale of securities to advisory clients for which you or any
related person has any other sales interest (other than the receipt of sales
commissions as a broker or registered representative of a broker-dealer)?
Investment or Brokerage Discretion
C. Do you or any related person have discretionary authority to determine the:
Yes
No
(1) securities to be bought or sold for a client’s account?
(2) amount of securities to be bought or sold for a client’s account?
(3) broker or dealer to be used for a purchase or sale of securities
for a client’s account?
(4) commission rates to be paid to a broker or dealer for a client’s securities
transactions?

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