FIND A HARTWELL & COMPANY FINANCIAL ADVISOR NEAR ME

Proprietary Interest in Client Transactions
A. Do you or any related person:
(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)? NO
(2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients? YES
(3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (other than those mentioned in Items 8.A.(1) or (2))? NO

Sales Interest in Client Transactions
B. Do you or any related person:
(1) as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions)? NO
(2) recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any related person serves as underwriter or general or managing partner? NO
(3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of sales commissions as a broker or registered representative of a broker-dealer)? NO

Investment or Brokerage Discretion
C. Do you or any related person have discretionary authority to determine the:
(1) securities to be bought or sold for a client's account? YES
(2) amount of securities to be bought or sold for a client's account? YES
(3) broker or dealer to be used for a purchase or sale of securities for a client's account? NO
(4) commission rates to be paid to a broker or dealer for a client's securities transactions? NO
D. If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons? NO
E. Do you or any related person recommend brokers or dealers to clients? YES
F. If you answer "yes" to E. above, are any of the brokers or dealers related persons? NO
G. (1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") in connection with client securities transactions? YES
G. (2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of the Securities Exchange Act of 1934? YES
H. (1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals? NO
H. (2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm (cash or non-cash compensation in addition to the employee's regular salary)? NO
I. Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for client referrals? NO

A. (1) Do you have custody of any advisory clients':
(a) cash or bank accounts? NO
(b) securities? NO
(2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody:
(a) U.S. Dollar Amount $
(b) Total Number of Clients

B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients':
(a) cash or bank accounts? NO
(b) securities? NO
(2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons have custody:
(a) U.S. Dollar Amount $
(b) Total Number of Clients

C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply:
(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage. NO
(2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to the investors in the pools. NO
(3) An independent public accountant conducts an annual surprise examination of client funds and securities. NO
(4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodians for client funds and securities. NO

D. Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide to clients?
(1) you act as a qualified custodian NO
(2) your related person(s) act as qualified custodian(s) NO

E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide the date (MM/YYYY) the examination commenced:

F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as qualified custodians for your clients in connection with advisory services you provide to clients? 1