Subject: File No. 265-32
From: Jacob Hagop Yahiayan
Affiliation: Continental Advisory Services, LLC

January 13, 2021

I am following up on our discussion with Marth L. Miller with our family office www.continentaladvisory.com / www.tigressfinancialpartners.com, an IB and SEC registered RIA. We have developed EVA models to support SME capital formation support which current matrix lacks and augments bias.