NASD Rule 3040 Private Securities Transactions of an Associated Person

Pursuant to NASD Rule 3040 no associated person of the Company shall participate in a private securities transaction without first obtaining the prior written approval of the member firm. If the Company approves a person’s participation in a private securities transaction, the Company will record the transaction on its books and records.

The firm should complete the review of the participation of all associated persons for the month of December, 2011.