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Client Accounts
111. Customer complaints not being dealt with a timely manner
Our policy is to deal with customer complaints in a timely manner. If we discover that we have
not dealt with a complaint in a timely manner, our policy is to deal with it as soon as possible.

112. Customer complaints not being reported
Our policy is to deal with customer complaints in a timely manner. If we discover that a
complaint has not been reported to the CCO, our policy is to deal with the complaint as soon as we are made
aware of it and possibly terminate the offending employee.

113. Reduced fees or waived fees violating fiduciary duty or violating firm policy
(Need to add that "fees are negotiable")
Our policy is that fees are negotiable. With that said, if an advisor reduces fees without proper
approval, our policy may be to penalize the advisor in some way, possibly through reduced payout or even
termination.

114. New accounts not being provided all appropriate documents (contract, ADVs, Privacy, IPS)
Our policy is to deliver all required documents to each new account. If it is discovered that a new
account has not received all required documents, our policy is to deliver the missing documents as soon as
possible.

115. Not verifying or following CIP procedures
Our policy is to follow all AML rules. Much of the requirements fall on Schwab. However, we are
required to do our part, such as getting proper identification, not accepting certain forms of deposits and doing
some due diligence on the clients. Our policy for not following the rules is that we notify Schwab immediately
upon any suspicions we have and the offending employee will have to review the AML rules.

Supervision/Employees
116. Employee not being supervised (this includes IARs that are providing investment advice)
Our policy is to supervise all employees. However, due to the nature of the business, advisors are
often times alone with the client, not able to be directly supervised. Everyone is debriefed by the CCO regarding
client meetings and interactions. If an employee will not submit to the debriefings, then he is no longer being
supervised and our policy there is that the advisor has resigned. His regulatory status will be updated and he will
be notified of this action.

117. Hiring an employee that is disqualified
Our policy is to hire only qualified employees. If it is discovered later that they have been
disqualified, our policy is immediate dismissal.

118. Unlicensed personnel doing activities that would require registration
Our policy is to only allow licensed persons to do licensed activities. If an unlicensed person is
discovered to have done activities which require a license, our policy would be to have them review our policies &
procedures. If the infraction were substantial enough, they would be terminated.

120. Outside business activities not being reviewed and disclosed where appropriate
Our policy is to review outside business activities and disclose them to clients. If it is discovered
an advisor has an undisclosed OBA, we would require that it be disclosed or that he stop doing the OBA.

121. Firm employees not following firm procedures (i.e. Policies & Procedures , Code of Ethics, etc.)
Our policy is for employees to follow the P&P and COE. If we determine that an employee is not
following the P&P or COE, our policy is to have them review the P&P and COE. If the infraction requires it, the
employee may be terminated.