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Form Sec 1707 - Uniform Application For Investment Adviser Registration - Securities And Exchange Commission Page 40

Applicant:

SEC File Number:

Date:

FORM ADV

Part II - Page 5

801-

Participation or Interest in Client Transactions.

Applicant or a related person: (check those that apply)

As principal, buys securities for itself from or sells securities it owns to any client.

As broker or agent effects securities transactions for compensation for any client.

As broker or agent for any person other than a client effects transactions in which client securities are sold to or

bought from a brokerage customer.

Recommends to clients that they buy or sell securities or investment products in which the applicant or a related

person has some financial interest.

Buys or sells for itself securities that it also recommends to clients.

(For each box checked, describe on Schedule F when the applicant or a related person engages in these transactions and

what restrictions, internal procedures, or disclosures are used for conflicts of interest in those transactions.)

Describe, on Schedule F, your code of ethics, and state that you will provide a copy of your code of ethics to any client or

prospective client upon request.

Yes

10. Conditions for Managing Accounts. Does the applicant provide investment supervisory services, manage

investment advisory accounts or hold itself out as providing financial planning or some similarly termed

services and impose a minimum dollar value of assets or other conditions for starting or maintaining an

account?

(If yes, describe on Schedule F)

11. Review of Accounts. If applicant provides investment supervisory services, manages investment advisory accounts,

or holds itself out as providing financial planning or some similarly termed services:

A. Describe below the reviews and reviewers of the accounts. For reviews, include their frequency, different levels,

and triggering factors. For reviewers, include the number of reviewers, their titles and functions, instructions they

receive from applicant on performing reviews, and number of accounts assigned each.

B. Describe below the nature and frequency of regular reports to clients on their accounts.

Answer all items. Complete amended pages in full, circle amended items and file with execution page (page 1).

Form Sec 1707 - Uniform Application For Investment Adviser Registration - Securities And Exchange Commission Page 40