Frequently Asked Questions

CONDITIONS FOR MANAGING ACCOUNTS
REVIEW OF ACCOUNTS
INVESTMENT DISCRETION
PERSONAL AND PROPRIETARY TRADING
BROKERAGE RECOMMENDATIONS
ADDITIONAL COMPENSATION

CONDITIONS FOR MANAGING ACCOUNTS
For Portfolio Management Services, GWM requires a minimum account size of $1,000,000.

This account minimum may be negotiable based on the length or scope of the client relationship or the nature of the prospective relationship.

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REVIEW OF ACCOUNTS
Reviews: Accounts managed by GWM are monitored on a continuous basis and reviewed on at least a monthly basis by Michael Freeburg. Accounts are reviewed for consistency with the investment policy guidelines of the client. More frequent reviews may be triggered by changes in the client's individual needs and circumstances, the client's investment policy guidelines, by events related to the issuer of a security, or by market, economic or political events.

In addition, GWM will review each client account that incurs a portfolio loss in excess of 5% over the course of certain periods.

Third Party Investment Managers and the accounts managed by them will be reviewed by Mr. Freeburg on a quarterly basis or as otherwise agreed upon at the inception of the client agreement.

Reports: For accounts managed by GWM on the Trader Workstation ("TWS") platform, daily account statements, which include position and transaction information, are available to clients over the internet. Clients are primarily responsible for requesting the account statements through the TWS platform, however, GWM will download and send an account statement upon request. In addition, GWM will provide performance reports on a quarterly or monthly basis, as agreed upon.

For clients with accounts on a custodial platform other than TWS, the types of reports and the frequency with which the reports are provided will depend on the platform. GWM will at the inception of any account relationship that directs the use of a platform other than TWS advise the client of the types of reports and the frequency with which such reports will be provided to the client.

For Third Party Investment Manager and Monitoring Services, the types of
reports and the frequency of reporting will be as contracted for.

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INVESTMENT DISCRETION
For clients whose accounts are managed by GWM through the Trader Workstation ("TWS") platform of Interactive Brokers, LLC, GWM must be provided with discretionary trading authority to effect trades in the client's account. The client will retain the right to direct GWM to effect trades in the client's account.

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PERSONAL AND PROPRIETARY TRADING
GWM has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. GWM's Code of Ethics describes the firm's fiduciary duties and responsibilities to clients, and sets forth GWM's practice of supervising the personal securities transactions of supervised persons with access to portfolio recommendations and transactions. Individuals associated with GWM may buy or sell securities for their personal accounts identical to or different than those recommended to clients. It is the expressed policy of GWM that no person employed by GWM shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients.
To supervise compliance with its Code of Ethics, GWM requires that anyone associated with this advisory practice with access to advisory recommendations or transactions provide initial and annual securities holdings reports and quarterly securities transactions reports to the firm's Chief Compliance Officer. GWM requires such access persons also to receive approval from the Chief Compliance Officer prior to investing in any IPO's or private placements (limited offerings).

GWM requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. GWM's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to discipline.
GWM will provide a complete copy of its Code of Ethics to any client upon request to the Chief Compliance Officer at GWM's principal address.

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BROKERAGE RECOMMENDATIONS
GWM recommends the Trader Workstation ("TWS") platform offered to independent investment advisers by Interactive Brokers, LLC, a registered broker dealer and FINRA member. Clients in need of brokerage and custodial services will have Interactive Brokers, LLC recommended to them. As part of the TWS platform, except for direct debiting of fees, GWM will receive the same services and benefits that the client would receive if the client used the TWS program without the advisory services of GWM (See the disclosure under Item 13.A. of this Schedule F narrative). Clients are not under any obligation to effect trades through TWS. All clients are free to select any broker dealer and any custodian of his or her choice. GWM will not recommend the brokerage or custodial services of Saxony Securities, Inc. for advisory clients who engage GWM for portfolio management services.

GWM has reviewed the TWS platform and recommends TWS based on a number of factors. These factors include GWM's experience with TWS, the broker's reputation, the quality of execution services available through TWS, and the low transaction and custodial costs available through TWS. Clients who participate in TWS will pay transaction costs of 1/2 cent per share for stock transactions, subject to an overall minimum charge of $1.00 per transaction.

Based on its business model, GWM will not seek to exercise discretion to negotiate commission rates among various brokers on behalf of clients. GWM may, however, periodically attempt to negotiate lower commission rates for its clients with Interactive Brokers. Based on GWM's knowledge of the TWS program, GWM does not expect to be able to negotiate or obtain lower transaction costs.

Clients must direct GWM to use a particular broker dealer to effect securities transactions in the client's account. In directing the use of a recommended broker dealer, it should be understood that GWM will not have the authority to negotiate commission among various brokers, and best execution may not be achieved. Many clients, when undertaking an advisory relationship, already have a pre-established relationship with a broker and they will instruct GWM to execute all transactions through that broker. In the event that a client directs GWM to use a non-recommended broker dealer, it should be understood that not only will GWM not have authority to negotiate commissions among various broker dealers and may not be able to achieve best execution, but that GWM will not be able to obtain volume discounts and a disparity in commission charges may exist between the commissions charged to other clients.

Clients who are referred to a third party investment manager should refer to the disclosure document(s) of such manager for information on the brokerage recommendations and trading practices for those entities. Mr. Freeburg in his separate capacity of registered representative of Saxony Securities, Inc. will not act as a broker for any recommended Third Party Investment Manager.

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ADDITIONAL COMPENSATION
As disclosed in Item 1.D. of this Schedule F, GWM may act as a solicitor for various registered investment advisers, and for doing so will receive an ongoing solicitation fee of 0.25% assets under management for any clients referred by GWM to another advisory firm. GWM is aware of the special considerations promulgated under Rule 206(4)-3 of the Investment Advisers Act of 1940. As such, appropriate disclosure shall be made and all applicable Federal and State laws will be observed.

Clients in need of brokerage and custodial services will have the Trader Workstation ("TWS") program offered by Interactive Brokers recommended to them. As part of the TWS program, except for the direct debiting of fees, GWM will receive the same services and benefits that the client would receive if the client used the TWS program without the advisory services of GWM (See the disclosure under Item 12.B of this Schedule F narrative). The services and benefits that GWM and customers of TWS will receive from Interactive Brokers include an online trading platform, routing of trade orders to the low cost market for the security, execution, clearance and settlement of the trade order into the client's account, custody of client funds and securities, block trading capability, which provides the ability to aggregate securities transactions and then allocate the appropriate shares to accounts, pricing information and position and trade reporting. The one service that Interactive Brokers will provide to GWM that clients would not obtain for themselves if they did not use the services of GWM or another investment adviser is a fee calculation and direct debit service. With this service, TWS will calculate and and deduct advisory client fee based on the assets under management held in the account.

For clients who wish to direct the use of other broker dealers and other custodial platforms, GWM may receive benefits and services that it would not receive if it did not offer investment advice.

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