Mark Alan Miller

THE INVESTMENT ADVISER REPRESENTATIVE (IAR) CURRENTLY SERVES AS A CO-TRUSTEE (IN HIS INDIVIDUAL NAME) FOR SEVERAL TRUSTS, INCLUDING PERSONAL FAMILY TRUSTS. AS CO-TRUSTEE, SOME INVESTMENT RELATED RESPONSIBILITIES ARISE, INCLUDING PLANNING, TRADING, AND MONITORING. ALL CO-TRUSTEE OPERATIONS ARE CONDUCTED AT THE OFFICE AND THROUGH THE ADDRESS OF MILLER CAPITAL. THE START DATE FOR CO-TRUSTEE RELATIONSHIPS WAS JUNE 2000 THROUGH THE PRESENT. IT IS ESTIMATED THAT FIVE TO TEN HOURS PER MONTH ARE RELATED TO TRUSTEE RESPONSIBILITIES, WITH MOST HOURS OCCURRING OUTSIDE OF SECURITIES TRADING HOURS. ALTHOUGH MILLER CAPITAL IS NOT PERMITTED TO SERVE AS A TRUSTEE OR EXECUTOR, IT DOES PERMIT QUALIFIED PROFESSIONALS OF THE FIRM TO SERVE IN THESE TYPES OF FIDUCIARY ROLES FOR INDIVIDUALS, TRUSTS AND ESTATES, BUT ONLY: UPON REQUEST OF THE INDIVIDUAL, TRUST, OR ESTATE, BASED ON A PRE-EXISTING RELATIONSHIP WITH THE PROFESSIONAL WHICH IS UNRELATED TO THEIR RELATIONSHIP WITH AN INVESTEMENT ADVISOR, WITHOUT SOLICITATION BY THE FIRM OR THE PROFESSIONAL, SUBJECT TO APPROVAL BY THE FIRM. MILLER CAPITAL CONSIDERS FIDUCIARY SERVICES PROVIDED BY A PROFESSIONAL OF THE FIRM TO BE A PERSONAL SERVICE IN THEIR INDIVIDUAL CAPACITY, AND THE SOLE RESPONSIBILITY OF THE PROFESSIONAL. HOWEVER, FIRM POLICIES AND PROCEDURES MUST BE FOLLOWED FOR ALL PERSONAL FIDUCIARY APPOINTMENTS, INCLUDING THE GUIDELINES OF OUR COMPLIANCE PROGRAM AND CODE OF ETHICS. FOR THIS REASON, THE FIRM MUST BE PROVIDED WITH ALL APPLICABLE INFORMATION ON THE INVESTMENT OPERATIONS RELATED TO THE FIDUCIARY RELATIONSHIP SO THAT THE FIRM CAN MONITOR COMPLIANCE WITH ITS COMPLIANCE PROGRAM AND CODE OF ETHICS. TO ASSIST THE FIRM IN REVIEWING ADHERENCE TO IT'S COMPLIANCE PROGRAM AND CODE OF ETHICS BY PROFESSIONALS OF THE FIRM THAT ARE PROVIDING FIDUCIARY SERVICES IN AN INDIVIDUAL CAPACITY, THE FIRM REQUESTS FIDUCIARY ASSETS TO BE ACCOUNTED FOR USING ITS PORTFOLIO MANAGEMENT SYSTEM AND OTHER FIRM RESOURCES IN CARRYING OUT THEIR FIDUCIARY OBLIGATIONS, THE PROFESSIONAL MUST DISCLOSE IN WRITING THAT MILLER CAPITAL IS NOT A PARTY TO THE FIDUCIARY SERVICES AND IS NOT RESPONSIBLE FOR PROVIDING ANY MONITORING OR REVIEW OF SUCH FIDUCIARY SERVICES. THE PURPOSE OF THIS REQUIRED DISCLOSURE IS TO CLEARLY COMMUNICATE TO THE INTERESTED PARTIES IN THE FIDUCIARY RELATIONSHIP THAT MILLER CAPITAL IS NOT INVOLVED IN A PROFESSIONAL RELATIONSHIP WITH THEM AND IS NOT WORKING ON THEIR BEHALF. WHILE ALL FEES RELATED TO THE FIDUCIARY APPOINTMENT BECOME THE PROPERTY OF THE FIRM UNDER OUR POLICIES AND PROCEDURES, MILLER CAPITAL RETAINS NO DUTY TO SUPERVISE THE PROFESSIONAL'S FIDUCIARY SERVICES PROVIDED IN AN INDIVIDUAL CAPACITY, EVEN IF PROVIDED FOR AN INDIVIDUAL THAT IS ALSO A CLIENT OF THE FIRM. BECAUSE THE FIRM RECEIVES INFORMATION ON THE FIDUCIARY INVESTMENT ACTIVITY FOR COMPLIANCE PURPOSES, THE FIRM LISTS THE FIDUCIARY ACCOUNTS IN THEIR FILING WITH THE SECURITIES AND EXCHANGE COMMISSION, FORM ADV, PART I. HOWEVER, THIS FILING DISCLOSES THE NUMBER OF ACCOUNTS AND VALUE OF ACCOUNTS THAT ARE RELATED TO FIDUCIARY SERVICES PROVIDED BY A PROFESSIONAL OF THE FIRM IN AN INDIVIDUAL CAPACITY AND THEREFORE ARE NOT SUPPORTED BY AN INVESTMENT AGREEMENT WITH MILLER CAPITAL.