Subject: File No. 4-606
From: Richard D Parks
Affiliation: Managing Partner

August 26, 2010

We are currently reviewed Annually by our Compliance Department and complete the Firm Element and questionnaire. All email correspondence sent to clients with any form of recommendation is reviewed for compliance and suitablility.

We take great measures to Supervise our newly licensed individuals and actively train and review their transactions on a continuous and competent basis.

Recommendation are made to clients based on ther cirucumstances known at the time of doing business and reviewed on a periodic or sooner basis with clients. All transactions are documented in the Representatives Blotter and monitored by several layers of management. We actively review our books of business and way of doing business.

Regards, Rick