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Selection of Money Manager for Clients

Clients will be interviewed by a CCAM financial consultant who will obtain necessary information regarding the client's financial condition, sophistication, and investment objectives. The interview process includes the development of a client profile regarding financial condition, investment objectives, risk tolerance, liquidity requirements and time horizon. Based on CCAM's understanding of the client's investment needs and objectives as obtained by the interview process, CCAM will recommend one or more investment managers from those participating in the program whose investment philosophy and objectives CCAM believes are most compatible with the client's investment philosophy and objectives. CCAM notifies the client-selected investment manager(s) and provides them with copies of the client's questionnaire and any investment policies and restrictions provided by the client to CCAM in writing. Clients are regularly encouraged to, and are responsible for, bringing material changes in objectives or financial condition to the attention of their introducing financial consultant at CCAM. Changes in objectives and financial condition that CCAM deems material or noteworthy will be communicated to the client's investment manager(s). Investment managers may also have similar communications with clients.

Both CCAM and client-chosen investment managers have discretionary authority. Other than in connection with its consulting responsibilities, CCAM does not assume responsibility for the conduct of the investment managers including, but not limited to, their performance or compliance with applicable laws or regulations. Clients are advised and are expected to understand that an investment manager's past performance is not a guarantee of future results and that certain market and economic risks exist that may adversely affect a manager's performance which could result in capital losses in that client's account. The selection of risk parameters and comparative indices by CCAM with which to compare a client's account performance are for informational purposes only. No guarantee is expressed or implied that the client's account performance will compare favorably to such parameters or indices.