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74. Principal or cross trades not done in compliance with advisers act or SEC guidance
Our policy is to not participate in principal trades or cross trades.

75. Errors not caught and addressed in a timely manner
Our policy is to catch any trade errors as soon as possible. If a trade error is not caught in a
timely manner, it is treated as any other trade correction, by correcting the trade and any loss goes against the
firm.

76. Errors/Corrections not identified and resolved in client's best interest
Our policy is to catch any trade errors as soon as possible. If a trade error is not caught in a
timely manner, it is treated as any other trade correction, by correcting the trade and any loss goes against the
firm.

Non-public Information
81. Use of client trading to manipulate price of publicly traded stock
Our policy is to not trade in such a manner as to influence the price of a stock.

83. Internal safety protocols breached
Our policy is to ensure the safety of client information. If internal protocols have been breached,
then our policy is to determine the extent of the breach and notify any affected clients and offer 1 year of credit
monitoring.

84. Non-access persons having access to non-public information
Our policy is to ensure the safety of client information. Only certain people are allowed access to
non-public information. If a non-access person were to access non-public information, our policy would be to
determine the extent of the breach and notify any affected clients and offer 1 year of credit monitoring.

85. Clients not being made aware of firms privacy policy initially and annually
Our policy is to issue a copy of our privacy policy annually. If a client does not receive the privacy
policy, it is our policy to make sure he gets one as soon as possible.

86. Clients not being notified in case of breach
Our policy is to ensure the safety of client information. If internal protocols have been breached,
then our policy is to determine the extent of the breach and notify any affected clients and offer 1 year of credit
monitoring. If a client has not been notified, it is our policy to notify him as soon as the discovery is made.

87. Inappropriate disposal of non-public information
Our policy is to ensure the safety of client information. When disposing of non-public
information, we destroy the medium on which it was stored. If we discover that non- public information was
disposed of inappropriately, we would treat it the same as a breach. Our policy is to determine the extent of the
breach and notify any affected clients and offer 1 year of credit monitoring.

88. Inappropriate transmittal of non-public information
Our policy is to ensure the safety of client information. If it is discovered that non-public
information has been transmitted inappropriately, our policy is to review the cybersecurity guidelines with the
offending party. If it continues, we would require they have all emails reviewed before being sent.

Personal/Proprietary Trading/Code of Ethics
89. Not maintaining accurate list of "Access Persons"
Our policy is to maintain a list of Access Persons. If it is discovered that our list is not up to date,
our policy is to bring it up to date as soon as possible.