I use fundamental analysis to purchase undervalued securities. Most of my analysis emphasized the purchase of securities selling at discounts to their liquidation values. I use analysis popularized by Benjamin Graham. There are also short sales of fundamentally overvalued securities. I diversify widely by asset class and also invest on a worldwide basis. My goal is to create, on a continuous basis, a portfolio that is less volatile than an “orthodox” portfolio, but which also receives most of the return achieved by the more aggressive portfolio.

I also purchase securities that I recommend for my clients. The amounts are non-material and, in my opinion, do not affect the price of the security. I buy (and sell) for my clients based on need, availability of cash, and the size of the existing holdings (if any). The size of the purchase is based on the overall portfolio total and a risk tolerance adjustment. Those with the greatest need for the holding receive the allocation first. Allocations are determined by use of numerous linked Excel spreadsheets. The Excel files are categorized by security type and may also be further sorted to include foreign or domestic properties. There are spreadsheets tracking: 2. debt issues, 3. gold and precious metals, 4. real estate and real assets 6. Domestic and International Stock/Mutual Funds and Short Sales, 7. arbitrage, 8. variable rate investments, and 10. other fixed rate assets. The Excel spreadsheets are updated each weekday with the prior day’s trading and repriced as needed. Portfolio balance adjustments are done quarterly or as needed if significant changes have occurred.

I provide continuous review of all client accounts for both investment management and financial planning. Clients receive monthly statements from Fidelity, quarterly billing statements from me, an annual investment policy statement, an annual financial planning summary, general reports issued every six weeks and we also talk and meet on an “as-needed” basis. We have deliberately moved away from short-term performance reports as it undermined the long-term investment approach.

I have limited trading authorization from Fidelity Institutional Brokerage Services. The powers limit access to the accounts to buying and selling securities. Automatic Advisor billing has also been established with written client permission.

We advise clients to vote on proxy statements when necessary. The client is then responsible for voting their proxies. To date, we have not offered any advice on voting.

I use Fidelity Institutional Brokerage Services for all client brokerage accounts. They were chosen for their low cost, efficiency and flexibility. The commission has been negotiated to the current level and negotiations continue on an "as needed" basis. Although other brokerage houses may show lower commission schedules, we believe that Fidelity provides the best combination of execution price, commission fees and service. I have no financial relationship with Fidelity Brokerage Company. I also am listed as an advisor for client TIAA-CREF accounts (403B, RA and GRA). Again, there is no financial relationship with TIAA-CREF.

Orders are placed in block trades, which are then allocated to clients based on the criteria listed in Item 9E above. No advisory accounts are favored over others and all allocations are based solely on need and availability of cash (if trade is a purchase). Clients are treated fairly and equitably in allocation decisions and all allocations are directed solely to client accounts (ie- there are no other entities with advisory accounts)