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49. Suitability information not kept current
Our policy is to update a client’s suitability as their situation changes. If it is discovered that
suitability is not current, our policy is to update it as soon as possible.

50. Investment objectives miscommunicated or not clearly understood
Our policy is to understand each client’s investment objectives, and to confirm those investment
objectives at various points throughout the relationship. If it is discovered that we have misunderstood the client’s
investment objectives, it is our policy to get a clarification from the client as soon as possible.

51. Adviser influences client to accept higher risk than desired
Our policy is to determine the client’s risk and invest accordingly. If it is determined that an
advisor has influenced a client to accept higher risk than they desired, then the client’s portfolio would be adjusted
down to the level at which they are comfortable. If the advisor has shown that they have ignored client’s risk
tolerances, they may be terminated.

52. Failure to reconcile information communicated to portfolio manager and strategy implemented
Our policy is to have the advisors discuss strategy directly with the portfolio manager with almost
every change in the portfolios. Our policy if there is a miscommunication between the advisor and the manager is
to correct any error immediately, with any loss incurred by the client absorbed by the firm.

53. Portfolios not consistent with client's investment objectives
Our policy is to have the client’s portfolios match their objectives. If a portfolio is discovered to
be out of line with the objectives, then the portfolio manager brings it back into line as soon as possible.

54. Restrictions not monitored
Our policy is to note any restrictions a client may have and to follow them. If it is
discovered that we have not followed a restriction, then the trade is reversed and any loss incurred by the client is
absorbed by the firm.

55. Unsuitable transactions in client accounts
Our policy is to follow the suitability requirements of the client. If it is discovered that an
unsuitable security has been bought in the client’s portfolio, then the trade is reversed and any loss incurred by
the client is absorbed by the firm.

Trading and Allocations
57. Preferential trade allocation (family friends, special clients, for referrals)
Our policy is to trade all accounts through block trading whenever possible. This way, no one is
given preferential treatment. If it is discovered that someone has been given preferential treatment, then the
trade will be reversed at the cost of the firm or the advisor, whomever the offending party was.

58. Side by side management conflict or any other conflict not being disclosed
Our policy is to is to disclose pertinent known conflicts. If a conflict arises that has not been
disclosed, it is added to the proper documents and disclosed as soon as possible.

59. Investments outside client objectives or restrictions
Our policy is to follow the suitability requirements of the client. If it is discovered that an
unsuitable security has been bought in the client’s portfolio, then the trade is reversed and any loss incurred by
the client is absorbed by the firm.

60. Allocations are consistent with what firm has disclosed
Our policy is not to disclose our performance numbers or asset allocation since each client may
have a different asset allocation. If a portfolio is found to be substantially out of our internal allocations, our policy
is to review the account to determine why the allocation is different and to bring it in line if there is no external
reason (Client just withdrew a large sum of money, client has a large position in a security they like…)