Client's Bill of Rights

Dear Investor,

Investing is a serious business. That is exactly why we believe you should have every opportunity to understand the risks, rewards and implications of the products, services, and investment and financial planning strategies offered to you for your consideration. With that in mind, we are providing you with this explanation of Your Rights and Responsibilities as an investor. I encourage you to invest a little time now and read this document. Our investment philosophy goes beyond the primary objectives of preservation of principal, generation of income and capital appreciation. While there is little doubt that these are important objectives for you, a personalized investment plan requires even more; e.g., peace of mind, exemplary service and education. I believe it is critically important that you understand the investment process and your rights and obligations as an investor so that you may better utilize our support. To that end, I am asking that you take the time now to review Your Rights and Responsibilities before proceeding further with your investment program.

Sincerely,

Thomas A. James Chairman of the Board   

A client is entitled to courteous service from a Financial Advisor and all other representatives of a securities firm. A client has the right to work with a trustworthy professional who is competent in securities investing and financial planning matters and who will perform ongoing portfolio reviews, as well as communicate on a regular basis; to ask for and receive information from a firm about the work history and background of the person and securities firm handling your account; and to contact your state or provincial securities agency to verify the employment and disciplinary history of a securities salesperson and the salesperson's firm. All investment and financial planning recommendations should be based upon the client's needs and objectives. A Financial Advisor is responsible for assisting a client in the diversification of his or her investments through allocations among asset classes and individual securities. In the event a client initiates an investment decision without the benefit of or against the advice of the Financial Advisor, the order ticket and confirmation will be marked "unsolicited," reflecting that the decision is the responsibility of the investor. For accounts managed by a professional money manager, the order ticket and confirmation will reflect that the decision is the responsibility of the money manager, not the Financial Advisor. Each client has the right to expect that recommendations will be made consistent with the objective of enhancing his or her financial well-being. While the performance of individual investments can fail to achieve reasonable expectations and markets can underperform their historical averages, a client has the right to receive recommendations based upon the goal of attaining superior performance in light of the facts and circumstances known at the time of investment selection. Unfortunately, performance cannot be guaranteed because Financial Advisors are not prescient; i.e., do not possess crystal balls. Reasonable alternative investments suitable for the client's individual objectives should be presented with full disclosure of both risks and costs, as well as benefits. A Financial Advisor should discuss reasonable, achievable results to prevent the formation of unreasonable expectations on the part of the client. Transactions should be executed in a timely fashion, at the best available price, with prompt reports to the client. A client has the right to know all costs and commissions associated with an investment, as well as fees the firm charges for its services. The only exception to the above is that the commissions and trading profits are included in the purchase price of a security traded in a principal capacity. Information should be communicated in an understandable fashion. Client statements should reflect all positions held and cash receipts and disbursements made by a broker/dealer. With the exception of infrequently traded securities, all positions should be priced as accurately as possible. Any complaints or errors should be addressed and, when necessary, corrected promptly. For trade errors, a corrected confirmation should be issued promptly and the subsequent client statement should reflect the correction. If a problem is not resolved to a client's satisfaction, the client has the right to contact the branch manager and/or our Client Services Department at 800-647-SERV (7378). Information about a client's financial situation will be kept confidential. A client has the right to select his or her Financial Advisor. In the event a client is uncomfortable or dissatisfied with a Financial Advisor, he or she has the right to ask the firm to suggest alternative professionals for consideration.