WHAT INVESTMENT SERVICES AND ADVICE CAN YOU PROVIDE ME? 

• We do not open brokerage accounts as is generally understood in the securities industry. You will pay us a transaction-based fee, generally referred to as a commission. Our registered representatives will recommend investments, however, these investments are not monitored on an ongoing basis. We offer only nondiscretionary services, which means the retail investor makes the ultimate decision regarding the purchase and/or sale of investments. We do not impose account or investment amount minimums. 

• Private placements are unregistered securities. If you establish a relationship with our firm as an investor, which we refer to as a customer, in a private placement offered by our firm on behalf of an issuer of securities, we generally will not charge you a fee, as it is the issuer who will generally pay us a transaction-based fee, most often referred to as a commission, every time a private placement transaction closes. Such fee would be based on a percentage of the funds we raised from you and, if applicable, other investors. You should be aware that whether directly or indirectly, a part of the funds you invest in a private placement may be used by the issuer to pay some or all of our fee. You should confirm with the issuer directly and also refer to the private placement documentation you are provided to further ascertain how your funds shall be used by the issuer. 

• At times, we may assist you in selling your ownership interest in a privately held security and we would in such event charge you a fee directly. 

• With respect to private placement securities, as a customer (an investor) the ultimate investment decision as to your investment strategy and the purchase or sale of investments will be yours. 

• You may select investments, or we may recommend investments to you, but the ultimate investment decision as to your investment strategy and the purchase or sale of investments will be yours. 

• We do not offer account monitoring services. 

• We offer for sale or purchase proprietary products. 

Conversation Starters. Ask your financial professional— 

• Given my financial situation, should I choose a brokerage service? Why or why not? 

• How will you choose investments to recommend to me? 

• What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean? 

WHAT FEES WILL I PAY? 

• Depending upon your investment, you will pay the following transaction-based fees: 

• Private Investments/Private Placements – you will pay a commission on the purchase of a private investment and on a private placement. The amount will depend on the offering. There will also be other expenses associated with the purchase. Please see offering memorandum for more information. 

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. Finally, please note the more money you invest the greater our fee will be. 

Conversation Starter. Ask your financial professional— 

• Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?