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133. Electronic records not being kept in accordance with SEC rules and regulations
Our policy is to maintain all required books and records. If we discover that they are not being
kept according to SEC rules & Regs, our policy is to ensure that they are.

Business Continuity/Succession Planning
134. Having no continuity and succession plan
Our policy is to have a continuity/succession plan. If we discover that we do not have the
required plan, our policy is to create one that meets the requirements.

135. Not testing the continuity plan for significant business disruptions
Our policy is to test our continuity plan. If we do not test it, our policy is to test it as soon as
possible.

136. Firm personnel not familiar with plan or not having access to the plan
Our policy is to have the succession plan available to employees. If we discover they do not
know where it is, our policy is to show them where and have them familiarize themselves with it.

137. Succession plan not being implemented
Our policy is to have a succession plan. Our policy is also not to have it implemented until
necessary. Our policy if it is not implemented when needed then the firm closes and advisors can take their clients
to their next firm.

Firm Compliance/Fiduciary Duty
138. Failing to conduct due diligence on third party service providers
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Our policy is to conduct due diligence on 3 party vendors. If we fail to do so, our policy is to
conduct the due diligence as soon as possible.

139. Not identifying firm's conflicts of interest
Our policy is to identify and disclose all conflicts of interest. If we discover a conflict not
previously identified, our policy is to identify it and disclose it as soon as possible.

140. Not disclosing all of firm's conflicts of interest to clients
Our policy is to identify and disclose all conflicts of interest. If we discover a conflict not
previously identified, our policy is to identify it and disclose it as soon as possible.

141. Violating firms fiduciary duty
Our policy is to comply with our fiduciary duty to our clients. If we discover a breach of that
duty, our policy is to correct it and disclose it if necessary.

Cybersecurity (Information Security)
142. Cybersecurity policy not being reviewed and properly updated
Our policy is to periodically review our cybersecurity and update as needed. If we discover that
we have not reviewed and updated, our policy is to review and update as soon as possible.

143. New staff members have not been properly informed and trained on cybersecurity policies
Our policy is to train all new employees on cybersecurity. If it is discovered that someone has not
been trained, then our policy is to train them as soon as possible.

144. Changes in firm cybersecurity policies not being provided to employees
Our policy is to periodically review our cybersecurity and update as needed. If we discover that
employees have not reviewed any updates, our policy is to have them review the updates as soon as possible.