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Referral Arrangements

CCAM may compensate, either directly or indirectly, any person (defined as a natural person or a company) for client referrals. CCAM and its principals may accept referral fees from investment advisers. It is anticipated that persons participating in referrals will be other Registered Investment Advisers, broker-dealers, law firms, pension consultants, real estate broker-dealers, and accounting firms. CCAM will comply with SEC and state regulations regarding disclosure, recordkeeping and other requirements.