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. Separately, ConvergEx's Millennium ATS' monthly Rule 605 report can be located at ftp://public.s3.com/rule605/nyfix/, with its quarterly Rule 606 report located at ftp://public.s3.com/rule606/nyfix/.

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

To all trade-matching parties providing trade orders to, acting on behalf of, or executing a trade with:

G-Trade Services LLC

This Trade-Matching Statement is being provided in accordance with National Instrument 24-101 - "Institutional Trade-Matching and Settlement" and Companion Policy 24-101CP [the "National Instrument"]. It applies to all trades that are subject to the National Instrument.

We confirm that we have established, maintain and enforce policies and procedures designed to achieve matching in accordance with the National Instrument.

BNY ConvergEx Execution Solutions LLC

Please click here for full trade confirmation details.

Single Stock Circuit Breakers – June 8, 2010

In accordance with the SEC plan to establish a market-wide trading pause for individual stocks in the S&P 500 Index, BNY ConvergEx Group, LLC (“ConvergEx”) will be in compliance with the new Single Stock Circuit-Breaker (SSCB) rule. The rule stipulates that if a stock falls/rises 10% in a 5-minute time period, then a market-wide trading pause will occur. The primary listing exchange will issue a halt message for the stock that meets the condition.

In the event the above market condition triggers an SSCB pause, ConvergEx’s matching systems, the ConvergEx Cross^SM, VortEx^® and the Millennium^SMATS, will halt trading in that stock. The ConvergEx Cross^SM,VortEx^® and Millennium^SMalternative trading systems will accept cancels and new orders while the stock is paused.

ConvergEx’s execution engines will not cancel open orders.

Be advised that the listed-options exchanges have indicated that they intend to halt trading in the related option series during a trading pause in the underlying stock. Orders associated with listed-options, subject to such halts, will be handled in accordance with the individual option exchange’s procedures.

If you have questions, please contact the Trade Support Desk for assistance at (212) 259-5590 or at tradesupportdesk@convergex.com.

Notification on Global Short Sale Restrictions – Ban in Germany – May 18, 2010

Several securities regulators around the globe have taken various actions in their home countries with respect to limiting or prohibiting “naked” short selling in some or all securities listed on exchanges or markets under their jurisdiction. For example, the Finance Minister in Germany is today expected to announce a ban on short selling of all German listed securities and government bonds. In April, the Hellenic Capital Market Commission in Greece announced a ban on short selling of securities listed in Athens. Press reports indicate that other regulators may be considering actions with respect to short sales as well. These actions will be different in each jurisdiction.

Under the customer agreement governing our relationship, you have agreed that all orders and transactions are subject to the laws, rules and regulations of the applicable jurisdiction and market.

BNY ConvergEx Group expects all customers to abide by the applicable short sales restrictions implemented by the various securities regulators. Under the circumstances, it is critically important that you settle all sell trades in a timely fashion, regardless of whether they are long sales or permitted short sales. Failure to settle on time potentially will result in an immediate buy-in and/or a request for proof that the sale was not a short sale.

BNY ConvergEx Group reserves the right, in its sole discretion and at any time, to reject any order to sell short and to cancel any short sale transaction.

Notification on Global Short Sale Restrictions - October 23, 2008

As we previously alerted you, securities regulators in a number of countries have taken various actions with respect to short selling in some or all securities listed on exchanges or markets under their jurisdiction. Each jurisdiction has enacted different rules and restrictions. To date, we are aware of actions by regulators in Australia, Austria, Belgium, Canada, France, Germany, Ireland, Italy, Japan, Luxembourg, the Netherlands, Switzerland, Taiwan, UK, and USA.

Under the customer agreement governing our relationship, you have agreed that all orders and transactions are subject to the laws, rules and regulations of the applicable jurisdiction and market.

BNY ConvergEx Group expects all customers to abide by the applicable short sales rules and regulations implemented by the various securities regulators, including any changes to those rules and regulations. Each order you send to us will be deemed your representation that such order and any resulting transaction and settlement are in compliance with all applicable laws, rules and regulations, including with respect to short sales. Please make sure you are well-versed in the laws, rules and regulations that apply to each order and transaction you submit or effect.

Under the circumstances, it is critically important that you settle all sell trades in a timely fashion, regardless of whether they are long sales or permitted short sales. Failure to settle on time potentially will result in an immediate buy-in without notice and/or a request for proof that the sale was not a short sale. BNY ConvergEx Group reserves the right, in its sole discretion and without notice, to reject any order and to cancel any transaction. The customer will be solely responsible for any and all losses and costs associated with any buy-ins, cancellations or borrows effected in order to close out a customer’s failed trade.

This notice does not constitute legal advice. You should seek advice from your counsel should have specific questions regarding any of the information contained herein.

Notice to Customers Regarding Information Collected for Customer Identification Purposes (“CIP”)

To help the government fight the funding of terrorism and money laundering activities, financial institutions, including the BNY ConvergEx Group of companies, are required by US Federal law to obtain, verify, and record information that identifies each individual or entity that opens an account or requests credit.

What this means for BNY ConvergEx Group customers: When a corporation, partnership, trust or other legal entity opens an account or requests credit, we will ask for the entity’s name, physical address and tax identification number, as well as any other information that will allow us to identify that entity, and may also ask to seek identifying documents, such as formation documents, business licenses, or similar materials.