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61. Inappropriate allocation on partial fills
Our policy is allocate according to the client’s objectives. This is done automatically through the
Black Diamond system and the Schwab trading platform. If it is discovered that a client received more or less than
they should have, a review is completed to see if there is an offsetting allocation error in another account, and if
not, to correct the allocation at the cost of the firm.

62. Failure to include required information on trade ticket
Our policy is to include all required information on a trade ticket. Since we use the automated
Schwab trading platform, this is done automatically for us. If we were to find that for some reason Schwab did not
include the proper information on the trade ticket, we would contact them to have them correct it.

63. Post-trade allocation procedures
Our policy is utilize the automatic allocation of the Schwab platform. We then verify the
accuracy of the allocations.

64. Trade allocations of bunched trades not allocated fairly
Our policy is utilize the automatic allocation of the Schwab platform. We then verify the
accuracy of the allocations.

65. Trades not being bunched when appropriate and in accordance with disclosures
Our policy is utilize block trading whenever possible.

66. Trades being executed by unauthorized personnel
Our policy is to have all trades done be a licensed person. If we were to find that an unlicensed
person placed a trade, we would review the trade for accuracy and note it. If this were a recurring occurrence, we
would terminate the employee.

67. Inappropriate trading patterns (pumping, window dressing, churning, turnover)
Our policy is to have all trades done by the money manager. Since we do not collect
commissions, there is no issue with churning. If it were discovered that window dressing or high turnover rates
were occurring, the trades would be reversed a the expense of the advisor.

Trade/Best Execution
69. Favoring broker based on research or referrals received
Our policy is to have all trades done through the Schwab platform. If it were discovered that we
were trading away from Schwab in exchange for research, we would stop the practice and charge the advisor with
any additional cost the clients may have been charged.

70. Periodic review of brokers for best execution - long term
Our policy is to have all trades done through Schwab. They offer a periodic review of the best
execution

71. Periodic review of transaction for best execution - short term
Our policy is to have all trades done through Schwab. They offer a periodic review of the best
execution. However, we also review trades on a short term basis, as they are done looking for any trades that
seem unusual. If a trade is found to be a price we do not expect, or see on the screen, we contact Schwab for an
explanation and correction if needed.

72. Disclosure of best execution policies
Our policy is to disclose that we have all trades done through Schwab. We also disclose that they
offer a periodic review of the best execution.

73. Principal or cross trades without required disclosure/consent
Our policy is to not participate in principal trades or cross trades.