DMC Group LLC

item 7 - types of clients                     condition and the quality of the company’s
                                              management. Earnings, expenses,
We provide advisory services primarily to     assets, and liabilities are all important in
individuals, high net worth individuals,      determining the value of a company. The
charitable organizations, other RIAs and      value is then compared to the current
corporations.                                 price of the issuing company’s security to
                                              determine whether to add, reduce, or
The minimum account sizes are:                maintain model exposure to an individual
 Wealth Management Customized                security.
   Solutions - $500,000 minimum
                                              Although we manage your portfolio in a
                                              manner consistent with your risk
                                              tolerances, there can be no guarantee
                                              that our efforts will be successful. You

3|Page

should be prepared to bear the risk of          item 11 - code of ethics,
loss.
                                                participation or interest in
Our investment strategies may include           client transactions and
long-term and short-term purchases and          personal trading
sales. You may place reasonable
restrictions on the strategies to be
                                                We have adopted a Code of Ethics
employed in your portfolio and the types
                                                (“Code”) to address the securities-related
of investments to be held in your portfolio.
                                                conduct of our supervised persons. The
                                                Code includes our policies and
All investments involve risks that can
                                                procedures developed to protect your
result in loss:
                                                interests in relation to the following:
 loss of principal,                             the duty at all times to place your
 a reduction in earnings (including                interests ahead of ours;
     interest, dividends and other
     distributions), and
                                                 that all personal securities transactions
                                                    of our supervised persons be
 the loss of future earnings.                      conducted in a manner consistent with
Additionally, these risks may include:              the Code and avoid any actual or
 market risk,                                      potential conflict of interest, or any
 interest rate risk,                               abuse of a supervised person’s
 liquidity risk,                                   position of trust and responsibility;
 issuer risk, and                               that supervised persons may not take
 general economic risk.                            inappropriate advantage of their
                                                    positions;
item 9 - disciplinary                            that information concerning the identity
                                                    of your security holdings and financial
information                                         circumstances are confidential; and
We have not been the subject of any legal
                                                 that independence in the investment
                                                    decision-making process is
or disciplinary events that would be
                                                    paramount.
material to your evaluation of our
business or the integrity of our
                                                We will provide a copy of the Code to you
management.
                                                or any prospective client upon request.
item 10 - other financial                       We do not buy or sell securities for our
industry activities and                         firm that we also deploy for clients. Our
affiliations                                    supervised persons are permitted to buy
                                                or sell the same securities for their
                                                personal and family accounts that are
Neither Greybox Investments or any of
                                                bought or sold for your account(s). The
our management persons is engaged in
                                                personal securities transactions by
other financial industry activities or has
                                                supervised persons raise potential
other industry affiliations that would create
                                                conflicts of interest when they trade in a
a material conflict of interest.
                                                security that is owned by you or
                                                considered for purchase or sale for you.

4|Page

                                                execution capabilities,
We have adopted policies and procedures         pricing, and
that are intended to address these              types and quality of research.
conflicts of interest. These policies and
procedures:                                    The lowest possible transaction cost is not
 require our supervised persons to act        the determining factor in the
   in your best interest,                      recommendation of a broker-dealer to
 prohibit favoring one client over            execute transactions for your accounts,
   another, and                                but whether the firm can provide, in our
 provide for the review of transactions       view, the best qualitative execution for
...