Global Brokerage Services Inc

Types of Clients
GBS generally provides investment advisory services for Individuals, individual retirement accounts (“IRAs”), pension and profit-
sharing plans, including plans subject to ERISA, and trust.

GBS can prohibit anyone or any account type from establishing a Program Account for any reason, including if we believe it is
not an appropriate investment strategy for you.

      Item 6- Methods of Analysis and Investment Strategies and Risk of Loss

Your IAR is the sole portfolio manager available with respect to the Programs. Please refer to your IAR's Supplement to this
Brochure for information about his or her education and business experience. Your IAR must be properly registered and
approved by Global Brokerage Services, Inc.'s senior management, as a Portfolio Manager prior to the solicitation of the Wrap
Accounts.

Affiliated and unaffiliated service providers may develop asset allocation models. Your IAR may also develop asset allocation
models or use others from outside independent sources. Each representative develops his or her own methods of analysis,
sources of information, and investment strategies. As such, recommendations by representatives, individual investment
portfolios and performance will differ.

Your IAR will manage accounts on a periodic basis as outlined in the Management Agreement and will review accounts at least
annually with you (or more frequently upon your request). The purpose of the review is to review the portfolio and its
performance; to discuss any changes in your financial profile and investment goals; and, to recommend changes that may be
warranted. You may contact your IAR or Global Brokerage Services, Inc.'s Home Office when you have questions or concerns
about your account, financial situation, or investment needs. Please note that your IAR may not be readily available for
unscheduled or unannounced visits or calls.

Manager/Strategist Selection and Evaluation:

The Methods of Analysis used, and Investment Strategies for each Program are described here and below.

We use the following investment strategies, as appropriate, when managing client assets

Long-Term Purchases:
Where appropriate, GBS employs a long-term investment strategy when formulating the investment advice given to clients.
This entails the purchase of securities with the idea of holding them in your account for a year or longer. We do this when we
believe the securities to be currently undervalued. We also do this when we want exposure to a particular asset class over
time, regardless of the current projection for the class.

A risk in a long-term purchase strategy is that, by holding the security for this length of time, GBS does not take advantage of
short-term gains that could be profitable to you. Moreover, if our predictions are incorrect, a security could decline sharply in
value before we make the decision to sell.

Short- term Purchases:
Where appropriate, GBS also purchases securities with the idea of selling them within a relatively short time, typically a year or
less. We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities
we purchase.

A risk in a short-term strategy is that, should the anticipated price swing not materialize, GBS is left with the option of having a
long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this
strategy involves more frequent trading than does a longer-term strategy, and results in an increase in transaction-related cost,
as well as less favorable tax treatment of short-term capital gains.

Options:
Certain types of option trading are permitted in order to generate income or hedge a security held in the Partner-APM
program; namely, the selling (writing) of covered call options or the purchasing of put options on a security held in the Program
account. You should be aware that the use of options involves additional risks. The risks of covered call writing include the
potential for the market to rise sharply. In such a case, the option counterparty has the right to call away the security and the
Program account will no longer hold the security. The risk of buying long puts is limited to the loss of the premiums paid for the
purchase of the put if the option is not exercised or otherwise sold by the program account. Options involve risk and are not
suitable for all investors. You should read “Characteristics and Risk of Standardized Option” brochure provided by your IAR.
There are costs associated with options trading, and you agree to pay such costs.

Partner APM-Methods of Analysis
Each IRA has the independence to take the approach he or she believes is the most appropriate when analyzing investment
products and strategies for Clients in the Partner Program. There are several sources of information the GBS and/or IARs use as
part of the investment analysis process. These sources include, but are not limited to:

          •    Financial publications

          •    Research materials prepared by third parties

          •    Corporate rating services

          •    SEC Filings (annual reports, prospectus, 10-K, etc)

          •    Company press releases

          •    Regulatory and self-regulatory reports

          •    Other public sources

As a firm, GBS does not favor any specific method of analysis over another and therefore would not be considered to have one
approach deemed to be a “significant strategy.” There are, however, a few common approaches that GBS or your IAR, often
use individually or collectively, in the course of providing advice to Clients. Please note that there is no investment strategy
that will guarantee a profit or prevent loss. The following are some common strategies employs in the management of Client
accounts:

          •    Dollar Cost Averaging (“DCA”): The technique of buying a fixed dollar amount of a particular investment on a
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