Advisory Services

Portfolio Management Services
GWM provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, GWM develops a client's personal investment guidelines and creates and manages a portfolio based on those guidelines. GWM provides this service to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. GWM will manage advisory accounts on a discretionary or nondiscretionary basis.

Securities will be selected for inclusion in client portfolios based on factors such as the risk tolerance of the client, liquidity needs, the adequacy of portfolio diversification among markets, sectors, and industries, investment objectives and tax considerations. Clients will have the opportunity to place reasonable restrictions on the types of investments. Clients will retain individual ownership of all securities.

GWM also manages investment advisory accounts not involving Investment Supervisory Services. GWM will provide this service to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. GWM will manage non-supervisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income).

Each portfolio is designed to meet a particular investment goal which GWM and the client have determined is suitable to the client's circumstances. Once the appropriate portfolio has been determined, the portfolio will be continuously managed based on the portfolio's goal, rather than on each client's individual needs. However, each client will have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio.

Third Party Investment Manager and Monitoring Services
GWM will assist clients in selecting and monitoring independent third party investment managers. GWM will provide this service to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. Clients may obtain selection and monitoring services separately or in combination.

In selecting an independent third party investment manager, GWM will, on behalf of a client, perform searches of various managers who may pay referral fees to GWM. Based on personal discussions in which goals and objectives based on a client's individual needs are established, GWM will determine which manager or managers are appropriate for a client and make recommendations to the client. Factors considered in making this determination include account size, risk tolerance, the investment objectives and needs of the client, the investment management style and philosophy of the manager and the types of investment vehicles offered. When advisable, GWM will also assist the client in establishing the account relationship by developing the investment policy guidelines for the account. Clients should also refer to the independent investment manager's disclosure document for a full description of the services offered.

In monitoring the performance of an account managed by an independent third party investment manager, GWM will meet with the client, initially and thereafter on a regular basis or as otherwise agreed upon, to review the account against the investment guidelines of account or the investment objectives and goals of the client. If GWM believes that a particular asset class, investment vehicle or manager is performing inadequately, or that a different asset class, investment vehicle or manager would be more suitable for a client's particular needs, then GWM may suggest that the client re-balance or re-allocate its investments or contract with a different manager. The client may then instruct the manager to make any or all of the changes recommended by GWM or may terminate the account relationship with the manager. Implementation of GWM's recommendations must be performed by the client and is solely at the discretion of the client.