Compliance Statement

Disclosure of Order Execution and Routing Practices

(SEC Rule 605 and 606)

The SEC adopted two rules to improve public disclosure of order execution and routing practices. Under Rule 605, Market Centers that trade National Market System securities are required to make available to the public monthly electronic reports that include uniform statistical measures of execution quality. Rule 606 requires broker-dealers that route customer orders in equity and option securities to make publicly available quarterly reports that identify the venues to which customer orders are routed for execution.

You may locate our monthly report required under Rule 605 and our quarterly report required under Rule 606 at http://www.tta.thomson.com/ under ECUT- BNY ConvergEx and BNY ConvergEx Execution Solutions LLC respectively.

Restricted Stock Sales

Under the Securities Act of 1933, restricted stock may be offered or sold only pursuant to an effective registration statement filed with the SEC, or pursuant to an exemption from the Act's registration requirements. In 1972, the SEC adopted Rule 144 which provides a safe harbor for resales of restricted and control stock and provides an exemption from registration.

Clients should contact our trading desk directly in order to effect restricted stock sales.

Corporations Purchasing Their Own Stock

Rule 10b-18 under the Exchange Act provides issuers with a safe harbor from certain anti-manipulation rules and regulations on the condition that certain requirements relating to the price, time, and volume are met.

Clients should contact our trading desk directly in order to effect a repurchase of their own securities.

Customer Complaints

In accordance with SEC Rule 17a-3(a)(18)(ii), please be advised that customer complaints may be directed to the following address and/or telephone number:

BNY ConvergEx Group, LLC
1633 Broadway 48th Floor
New York N.Y. 10019
Attn: Compliance Department
(212) 468-7746

Investment Protection Principles

Merrill Lynch & Co., Inc. and New York State Attorney General Eliot Spitzer entered into an agreement, dated May 21, 2002, pursuant to which Merrill Lynch agreed to adopt certain principles in the conduct of its investment banking business (the "Investment Protection Principles").

BNY ConvergEx Group, LLC (“ConvergEx”) and its affiliates are dedicated to providing our clients with conflict-free service. ConvergEx and its affiliates do not have an investment banking business, do not make markets in any securities and do not take proprietary positions. Accordingly, ConvergEx and its affiliates’ business models have never raised the conflicts of interest the Investment Protection Principles were designed to address.

In other words, ConvergEx and its affiliates have complied with the Investment Protection Principles throughout their history and will continue to do so in the future.

G-Trade Services LLC

G-Trade Services LLC is an international dealer in Ontario and certain of its affiliates are also securities registrants in Ontario. G-Trade Services LLC has adopted policies and procedures to minimize the potential for conflict of interest resulting from the relationship.