We believe that the needs of the investor always take precedence, including the right to high-quality products and services. To that end, we have developed the following list of investor rights:

• Investors should be treated in a fair, ethical, and respectful manner in all interactions with their financial advisor.
• Investors have the right to competent and courteous service, and advice (if provided) at a fair price.
• Investors have the right to clear and accurate explanations of their transactions.
• Investors have the right to know and understand the commissions and fees associated with their accounts.
• Investor statements should provide timely and accurate account transactional information and should reflect all positions held.
• We will not sell, distribute, or make public any private investor or account information.
• Investors should expect their financial advisor’s assistance in helping them identify their investment goals and risk tolerance.
• Investors should expect their financial advisor’s assistance in setting realistic expectations about the potential long-term risk and return associated with different investments.
• Investors should be provided with responsible investment recommendations based on their objectives, time horizon, risk tolerance, and other factors they disclose to their financial advisor.
• Investors have the right to fair consideration and a prompt response should a problem arise with their accounts.

We believe that investors are responsible for following these basic principles:

• Investors should carefully read sales literature, prospectuses, and/or other offering documents before investing or sending money. They should carefully consider all risks and/or considerations contained in the documents.
• Investors should understand that all investments have some degree of risk and that it is possible to lose money in any investment.
• If seeking investment advice, investors are responsible for providing accurate information about their financial status, goals, and risk tolerance to ensure that appropriate recommendations are provided.
• Investors should promptly bring problems or questions concerning their accounts to the attention of their financial advisor.
• Investors should promptly notify their financial advisor whenever there are significant changes in their investment objectives, risk tolerance, income, net worth, or liquidity needs.
• Investors should make certain that they understand the correlation between risk and return.
• Investors should consult an attorney or tax advisor for specific legal or tax advice.
• Investors should review their portfolio holdings on a regular basis and whenever their financial circumstances change. They may want to make appropriate changes based on their investments’ performance and their current objectives.
• Investors choosing automated channels for their trading needs independent of their financial advisor (Internet or telephone) are fully responsible for their own investment choices.
• Investors should carefully consider the validity and reliability of investment information obtained from all sources, especially unsolicited information obtained over the Internet.