Disclosure

The web reports are not guaranteed to be fully reconciled against the custodian positions on a daily basis. OPCM makes every effort to provide the most accurate data available in the daily web reports. The market value of your portfolio(s) is determined based on the transaction data and price files received from custodians on a daily basis. The accuracy of data received by each custodian is reviewed and is a major factor considered in determining the primary source for pricing securities.

Market Data Manager is also used for the pricing of securities not priced via data feeds from custodians. In determining the net asset value of a portfolio, OPCM uses the following guidelines: (a) for marketable securities, the current market price will be used, (b) for securities for which there exists no active market (including unsupervised assets, privately or closely held securities and limited partnerships, real estate, and other fixed asset securities that are not priced via a national exchange), the firm shall use such information as it in good faith deems relevant to determine the value thereof and value the security periodically, which means the value shown on reports may lag the current market value (in the absence of a readily determinable value, such securities will be valued at cost), and (c) cash will be valued at its dollar value. OPCM shall use such information in good faith as deemed relevant to determine the value.

We urge you to compare account statements received from us with account statements received from your custodian on at least a quarterly basis. If your investment objectives and/or your financial circumstances have changed, please give us a call to schedule an appointment.

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