Individuals & Families

Resources & Education

Client Agreement and Disclosures

Text Size: Decrease Increase
Print
These disclosures include information about account service charges, account
protection, margin, business continuity, electronic delivery of account statements,
general terms and conditions, our privacy policy, and more.
For your records, an additional copy of the Client Agreement and Disclosures is
provided below. You initially received these documents when signing the Client
Agreement & Substitute W-9.

These disclosures include information about account service charges, account
protection, margin, business continuity, electronic delivery of account statements,
general terms and conditions, our privacy policy, and more. Please periodically
review these disclosures online at www.janney.com or by requesting a copy
of these materials from your Financial Advisor. These terms and conditions
fully apply to this and any new investment account(s) you open at Janney
Montgomery Scott LLC (“Janney”) and they may be modified or updated at any
time, at Janney’s sole discretion.

By signing the Client Agreement & Substitute W-9 (“Agreement”),
the client(s) (“You” or “Your”) agree to the following terms and
conditions and acknowledge the following disclosures:

YOUR SIGNATURE/FUTURE ACCOUNTS
The signature you provide on this Agreement governs the terms of the
accounts or services you are establishing now and that you add in the future.
When you open a new account or enroll in a service, we will provide you with
the agreement and any disclosures for that account or service and confirm
your enrollment in that account or service in writing. Those agreements and
disclosures are incorporated into this Agreement by reference. If the terms
governing an account or service are different from the terms outlined here,
the terms of that account or service will apply. This means that your initial
signature acts as your agreement to the terms of the new account or service.
As a result, in many cases, you will not need to sign an additional account
agreement or other form.


GENERAL TERMS AND CONDITIONS
You acknowledge and agree that all transactions and activity in all accounts
created from this Agreement will be governed by the rules, constitutions, customs
and usages of the exchange or market (and its clearinghouse, if any) where
executed, the rules and regulations of the Securities and Exchange Commission (“SEC”), the Federal Reserve Board and any other regulatory or self-regulatory agency having authority, and that the rights and obligations of the parties shall be determined in accordance with federal law and the laws of the Commonwealth of Pennsylvania, without regard to Pennsylvania’s conflicts of laws principles.

If you are a natural person or persons, you represent that you are of full legal
age in the state or jurisdiction in which you reside and that you are competent
to enter into this Agreement and perform the obligations under it. If you are
a fiduciary, trustee, corporate officer, partner or other representative of a legal
entity or entities, including a corporation, limited liability company, partnership,
limited liability partnership, estate or trust, you represent that such entity has
all necessary power and authority to execute and perform this Agreement
and that the execution and performance of this Agreement will not cause the
entity to violate any provisions in its charter, by-laws, partnership agreement,
trust agreement or other constituent, governing or operating agreement or
instrument. If you are a fiduciary, trustee, corporate officer, partner or other
representative of a legal entity or entities, you represent that you acting alone 
have full power and authority to deal with Janney on behalf of and without
notice to the legal entity or entities, any other joint owner or any other person
who has signed this Agreement. You further represent that this Agreement, as
amended from time to time, is a legal, valid and binding obligation, enforceable
against the entity (if not a natural person) in accordance with its terms. You, any
agents authorized by you to act on your behalf through a power of attorney or
limited trading authorization accepted and approved by Janney, and any agents
appointed by law will be the only authorized users of the brokerage and other
services under this Agreement.

This Agreement contains the entire understanding between you and Janney
concerning the subject matter of this Agreement, and you acknowledge that
there are no oral or other agreements in conflict herewith. This Agreement
will cover individually and collectively all brokerage accounts, whether in joint,
single or fiduciary capacity, which are opened by Janney for you. This Agreement
supersedes any previous agreements made by you individually, jointly, or in a
fiduciary capacity with Janney relating to any of your accounts, to the extent
the subject matter is covered in this Agreement. You may not assign the rights
and obligations of this Agreement without first obtaining Janney’s written
consent. Janney may amend this Agreement at any time by posting changes to
the Agreement on our website, www.janney.com. Your continued use of your
account(s) after the effective date of the revised Agreement as disclosed on
our website, or after a reasonable period of time if no such date is stated, will
constitute your acceptance of the revised Agreement. This Agreement shall be
binding upon, and shall inure to the benefit of, Janney, its successors or assigns,
you and your heirs, executors, administrators, trustees, receivers, successors or
assigns. If any provision of this Agreement is held to be invalid, that shall not
affect the validity of the remaining provisions of the Agreement.

You acknowledge and agree that the information that you have provided to
Janney for the purposes of establishing your account(s) is current, accurate,
truthful and complete. You agree to promptly notify Janney upon any changes
in such information, including, but not limited to, any changes in your selected
investment objectives or financial situation. No one except the person(s) or
entity(ies) listed on the Agreement has an interest in the account being applied
for. You agree to notify Janney in writing (a) if you or an immediate family
member is or becomes employed or affiliated with a broker-dealer, a U.S. stock
exchange or the Financial Industry Regulatory Authority (“FINRA”); or (b) if you
are or become an officer, director or ten percent (10%) or greater shareholder of
a U.S. publicly-traded company.

Whenever any statute shall be enacted which will in any way affect or be
inconsistent with any of the provisions hereof, or whenever any rule or
regulation shall be prescribed or promulgated by FINRA, the SEC, or any other
federal, state or self-regulatory committee which will in any way affect or be
inconsistent with any of the provisions hereof, the provisions of this Agreement
so affected will be deemed modified or superseded, as the case may be, by such
statute, rule or regulation, and all other provisions of this Agreement will in all
respects continue to be in full force and effect.

Janney may reject, cancel or modify any transactions that you have requested
at any time, for any reason without prior notice to you. Janney may suspend
or terminate your account at any time, for any reason and without prior notice
to you. You acknowledge that all employees acting on behalf of Janney do not
provide legal or tax advice. Complaints relating to your account(s) should be
forwarded to the Legal Department of Janney Montgomery Scott LLC, 1717 Arch
Street, Philadelphia, PA 19103 or call 1-800-526-6397.
Communications may be sent to you at your last address or at such other
addresses as you may hereafter give Janney, including any e-mail address if
provided by you, and all communications so sent, whether by mail, e-mail,
messenger or otherwise, will be deemed given to your personally, whether
actually received or not.

FEES, CHARGES AND COMMISSIONS
You agree to pay Janney its brokerage commissions, charges, or other fees.
Janney may change its brokerage commission rates without notice to you.
Janney’s Schedule of Account Service Charges is available on our website
schedule-of-account-service-charges or you may request a copy from
your Financial Advisor. Janney may change its fees at any time by posting the
changes to our website. Your continued use of your account(s) after the effective
date of any changes to the fees, or after a reasonable period of time if no such
date is stated, will constitute your acceptance of such fee changes.

PURCHASES AND SALES
In the event sufficient funds are not available in your account when a purchase
order is executed, you promise to pay the full amount due on or before the
settlement date for the purchase. In the event a sales order is executed and the
securities sold are not in your account, you promise to deliver all securities sold
on or before the settlement date. If such funds or securities are not received
on or before the settlement date, Janney may liquidate sufficient assets or
repurchase securities sold but not received into your account and you will be
liable for any resulting losses and all associated costs that Janney may incur as a
result of that liquidation or repurchase.

CASH DEBIT BALANCES
Janney may assess interest against a non-margin account in connection with any
debit balances resulting from your failure to make payment in full for securities
purchased, from proceeds of sales prior to settlement date, or for other charges
that Janney may make to the account. The following is the annual interest rate
that will be charged on all non-margin account debit balances (effective July 1,
2013):

Of the Debit Balance is: Percentage of Interest Charged:
Less than $25,000 Janney Base Rate plus 5.875%
Between $25,000 and $49,999 Janney Base Rate plus 5.25%
Between $50,000 and $99,999 Janney Base Rate plus 4.75%
Between $100,000 and $249,999 Janney Base Rate plus 4.25%
Between $250,000 and $499,999 Janney Base Rate plus 4.00%
Between $500,000 and $999,999 Janney Base Rate plus 3.75%
$1,000,000 and above Janney Base Rate plus 3.50%

Janney charges interest based on the Janney Base Rate (“Base Rate”). The Base Rate is an internally calculated rate established by Janney that changes from time to time based on Janney’s cost of funds and Janney’s assessment of the rates charged in the financial markets. The interest rate that you will be charged will increase or decrease as the Base Rate increases or decreases. The Base Rate will be published on Janney’s website and is subject to change without notice to you.

PAYMENT OF INDEBTEDNESS
If you become indebted to Janney, you agree to promptly and fully repay such indebtedness upon demand. Whenever you are indebted to Janney for any amount, all securities held by Janney for you in any account in which you have any interest will secure all your liabilities to Janney. You, jointly and severally, agree that if, after demand by Janney, you fail to promptly repay the indebtedness, Janney may, in its discretion at any time, close any or all of  your accounts and, without further notice, liquidate assets in any or all of your accounts by public or private sale or purchase or both in an amount sufficient
to pay your indebtedness, buy in (cover) short positions, cancel outstanding orders in whole or in part, and take any other appropriate or necessary action without incurring any liability whatsoever. All costs of collection and any unpaid deficiency in your account, including, without limitation, attorneys’ fees, incurred by Janney shall be fully reimbursed by you to Janney. Any balance remaining due to Janney shall be promptly paid by you. Any and all notices of purchase or sales or any demand for margin sent to you shall be binding upon you and upon your accounts. You, jointly and severally, agree that Janney shall have a lien on and may hold as collateral security for said account any and all securities and equities Janney may hold or have in any account at any time for you or any one of you and that the assertion or enforcement of any such lien shall not affect or
alter the liability of any of you for any debit balance or loss on said account. The provisions of this section shall not apply to an Individual Retirement Account (IRA) or account subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), except to the extent such indebtedness or liabilities arise with respect to that IRA or ERISA account.

PRE-DISPUTE ARBITRATION DISCLOSURE
This Agreement contains a pre-dispute arbitration clause. By signing an arbitration agreement, the parties agree as follows: 
(1) All parties to this Agreement are giving up the right to sue each other in court, including the right to a trial by jury, except as provided by the rules of the arbitration forum in which a claim is filed.
(2) Arbitration awards are generally final and binding; a party’s ability to have a court reverse or modify an arbitration award is very limited.
(3) The ability of the parties to obtain documents, witness statements and other discovery is generally more limited in arbitration than in court proceedings.
(4) The arbitrators do not have to explain the reason(s) for their award, unless, in an eligible case, a joint request for an explained decision has been submitted by all parties to the panel at least twenty (20) days prior to the first scheduled hearing date.
(5) The panel of arbitrators will typically include a minority of arbitrators who were or are affiliated with the securities industry.
(6) The rules of some arbitration forums may impose time limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration may be brought in court.
(7) The rules of the arbitration forum in which the claim is filed, and any amendments thereto, shall be incorporated into this Agreement. Any controversy between Janney and you arising out of Janney’s business, the Agreement or any of your accounts with Janney, shall be submitted to arbitration conducted under the terms of the Code of Arbitration Procedure of FINRA. In order to induce Janney to accept this Agreement, you agree that the laws of the Commonwealth of
Pennsylvania shall govern this Agreement, without regard to any conflict or choice of law provisions. No person shall bring a putative class action to arbitration, nor seek to enforce any pre-dispute arbitration agreement against any person who has initiated in court a putative class action; or who is a member of the putative class who has not opted out of the class with respect to any claims encompassed by the putative class until: (i) the class certification is denied or (ii) the class is decertified or (iii) the customer is excluded from the class by the court. Such forbearance to enforce an agreement to arbitration shall not constitute a waiver of any rights 
under this Agreement except to the extent stated herein.

If either Janney or your Financial Advisor is named as a party to a lawsuit, or incurs legal costs associated with a dispute regarding ownership or beneficiary interests of your assets at Janney, you agree that Janney will, at its sole discretion, be indemnified for those costs directly from your assets held at Janney.

NON-WAIVER OF RIGHTS
Janney’s failure to insist at any time upon strict compliance with any term of this Agreement, or any delay or failure on Janney’s part to exercise any power or right given Janney in this Agreement, or a continued course of such conduct on Janney’s part, shall at no time operate as a waiver of such power or right, nor shall any single or partial exercise preclude any other further exercise. All rights and remedies given Janney under this Agreement are cumulative and not exclusive of any other rights or remedies which Janney may otherwise have.

JOINT OWNERSHIP
In consideration of Janney carrying a joint account for you, you jointly and severally agree to be fully responsible and liable for your account and to pay on demand any debit balance or losses at any time due in this account. Each of you has full power and authority to make purchases and sales, withdraw monies and securities from it, obtain loans secured against securities in the account or do anything else with reference to said account, either individually or in your joint names, as either or any of you may elect, and Janney is authorized and directed to act upon instruction from any one of you.
If your account is a joint account with two or more owners, each joint owner agrees that each joint owner will have authority on behalf of all of the joint owners to deal with Janney as fully and completely as if each was the sole owner of the account, all without notice to the other joint owner(s). Notwithstanding the foregoing, each joint owner agrees that Janney may, at its sole discretion: (a) require joint instruction from some or all of the joint owners before taking action under this Agreement; and (b) if Janney receives instructions from any joint owner that are, in Janney’s opinion, in conflict with instructions received from any other joint owner, Janney may comply with any of these instructions and/or advise each joint owner of the apparent conflict and/or take no action as to any of these
instructions until it receives instructions from any or all of the joint owners that are satisfactory to it. Notice provided by Janney to any joint owner will be deemed notice to all joint owners. Each joint owner further agrees that it, he or she will be joint and severally liable for the account with each other joint owner.

If your account is designated as “Tenants in Common,” in the event of the death of either or any of the persons designated as tenants in common, the interests in the account shall be vested equally in the decendent’s estate and the survivor(s), unless different percentages (which must total 100%) are specified in a letter of instruction, which all account holders must have signed. By doing so, all holders acknowledge they have voluntarily agreed to such division amongst themselves and that they direct Janney to distribute their interests accordingly, without any liability thereafter.

If your account is designated as “Joint Tenants with Rights of Survivorship,” in the event of the death of either or any of the persons designated as joint tenants with rights of survivorship, the entire interest in the joint account shall be vested in the survivor(s) on the same terms and conditions as currently held, without in any manner releasing your estates from the liability provided in this Agreement.

If no designation is made for a joint account, each of you as joint owners directs
Janney to establish the account as “Joint Tenants with Rights of Survivorship.”

FIDUCIARY ACCOUNTS
A fiduciary is a person or entity authorized to make decisions with respect to an account on behalf of the account’s beneficial owner(s). A fiduciary is a trustee, custodian of an UGMA or UTMA account, conservator, guardian, executor, administrator, partner, attorney-in-fact, investment advisor or any other person or entity that represents a legal entity and has authority over a legal entity’s Janney account. You understand and agree that Janney does not review any action or inaction by a fiduciary and is not responsible for determining whether a fiduciary’s action or inaction satisfies the standard of care applicable to such fiduciary’s handling of the account. You further understand and agree that Janney is not responsible for determining the validity of a person’s or entity’s status or capacity to serve as a fiduciary. As a fiduciary, you agree to hold Janney and its officers, directors, employees, agents and affiliates harmless from any liability, claim or expense (including attorneys’ fees and disbursements), as incurred, for your actions or inactions. If the account has two or more fiduciaries authorized to make decisions, each fiduciary shall have full authority to deal with Janney as fully and completely as if each was the sole owner of the account, all without notice to the other fiduciary(ies), unless Janney is notified otherwise in writing. Notwithstanding the foregoing, Janney may, at its sole discretion: (a)
require joint instruction from some or all of the fiduciaries before taking action under this Agreement; and (b) if Janney receives instructions from any or all of the fiduciaries that are, in Janney’s opinion, in conflict with instructions received from any other fiduciary, Janney may comply with any of these instructions and/or advise each fiduciary of the apparent conflict and/or take no action as to any of these instructions until it receives instructions from any or all of the fiduciaries that are satisfactory to it.

TRUSTED CONTACT
Janney is required by regulation to ask if you would like to provide a Trusted Contact for your account. However, you are not required to provide a Trusted Contact. If you provide a Trusted Contact, you agree that Janney is authorized, without obligation and at the Firm’s sole discretion, to contact the Trusted Contact and disclose information about your account to address possible financial exploitation and to confirm the specifics of your current contact information, health status, and identity of any legal guardian, executor, trustee or holder of power of attorney. Janney may elect to notify an individual that they
have been named as a Trusted Contact, but is not required to do so. The Trusted Contact role is authorized only to share information and is not authorized to transact business on your behalf.

 

BANKRUPTCY, INSOLVENCY, REORGANIZATION, DISSOLUTION,
TERMINATION, INCOMPETENCY AND DEATH
You agree to promptly give written notice to Janney in the event of your
bankruptcy or insolvency, and if you are not a natural person, of your
reorganization, dissolution, termination or other similar condition. If you are a
natural person, you agree that your guardian will give Janney written notice of
your incompetency and that your estate will give Janney written notice of your
death. Janney may, before or after receiving notice of any of the conditions
described in this paragraph, commence any proceedings, require any documents,
retain any portion of or restrict transactions in the account, as it deems advisable
in its discretion to protect itself against any tax, liability, penalty, expense or
loss. If you are subject to any of the conditions described in this paragraph, you
and the remaining joint owners, as well as the estate of any deceased owner or
joint owner and each surviving joint owner will be liable, jointly and severally, to
Janney for: (a) any tax, liability, penalty, expense or loss in the account resulting
from the completion of transactions initiated prior to Janney’s receipt of a
written notice of the condition, and (b) any tax, liability, penalty, expense or loss
incurred in the liquidation of the account or the adjustment of the interests of
the joint owners, and (c) any other obligation owing with respect to the account.
If your account is a joint account, any tax, liability, penalty, expense or loss
becoming a lien against or payable out of the account as the result of any of the
conditions described above or through the exercise of any power by a trustee
or the representative of an estate will be chargeable against the interests of the
remaining joint owners or surviving owners, as well as the interest of the estate
and the beneficiaries of the estate. Each person indicated in the title to the
account who executes this Agreement agrees to give written notice to Janney in
the event of bankruptcy, insolvency, reorganization, incompetency or death of
any other joint owner.

PLATINUM DEBIT CARD
If you have selected the Platinum Debit Card option, you request that Janney
provide you with a debit card sponsored by BNY Mellon Services Corporation
(“BNY Mellon”) and authorize Janney to open an account in your name as it
appears on your Janney account, as an adjunct to your Janney cash or margin
account (“Brokerage Account”). You understand that you may be eligible
to borrow against margin through your Brokerage Account. You must check
with your Financial Advisor for details. You are herewith also applying to BNY
Mellon to establish a debit recordkeeping account in your Brokerage Account
and request that BNY Mellon provide you with one or more Platinum Debit
Card(s) for use with your Brokerage Account. Your Platinum Debit Card(s) will be
mailed to the address of record of your Brokerage Account. A Services Program
Information Statement and Agreement (“Information Statement”) will be sent
to you along with your new Platinum Debit Card(s). Your activation of your
Platinum Debit Card(s) indicates that you have received, read and agree to the
terms in the Information Statement.

A Personal Identification Number (“PIN”) is required when you use your
Platinum Debit Card at automated teller machines (“ATM”). Following receipt
of your Platinum Debit Card, you will need to activate your Debit Card by
contacting us. During the activation call, you will be requested to select a PIN.
ONLINE ACCOUNT ACCESS AND E-BILL PAYMENT SERVICES
Instruction on enrolling and using Janney’s Online Access and E-Bill Payment
Services can be found at www.janney.com. E-Bill Payment accounts which have
become inactive may be unenrolled after sixty (60) days of inactivity.

ERROR REPORTING
Trade confirmations are created immediately upon the completion of a
transaction in your account and are delivered to you. At a minimum, account
statements are delivered quarterly to you for all accounts maintaining a cash or
security balance. Moreover, statements are delivered to you monthly for accounts
in which transactions occurred during the month that affect those accounts’
balances or security positions.

Account statements and confirmations should be retained for your records. If you
do not understand an entry on your statements or confirmations, if you believe
that any of the information contained on your statements or confirmations is
incorrect, or if you believe that the statements or confirmations do not accurately
reflect transactions or other activity in your account, please submit an inquiry
to the Janney branch office manager of the office handling your account or to
Janney’s Compliance Department at Janney Montgomery Scott LLC, 1717 Arch
Street, Philadelphia, PA 19103 or call 1-800-526-6397.

ELECTRONIC FUNDS TRANSFER (“EFT”)
The EFT service enables you to invest or withdraw a specified amount between
your checking account at your local bank (as permitted) and your Janney account
each month. Once a month (on a date to be determined by you) the funds you
designate on the EFT application will be electronically transferred from your
bank account and deposited into your Janney account or withdrawn from your
Janney account and deposited into your bank account. If you wish to have funds
electronically transferred between your Janney account and your bank account,
please contact your Financial Advisor to obtain an EFT application. Please submit
the completed EFT application, along with a voided check from the bank account
to which your money is to be debited or credited each month. Janney requires
the signatures of all the bank account holders exactly as they appear on the
bank account if they differ from the holders of the Janney account.

LOSSES DUE TO EXTRAORDINARY EVENTS
Janney shall not be liable for loss caused directly or indirectly by war, natural
disaster or other acts of nature, terrorism, civil unrest, government restrictions,
exchange or market rulings, extraordinary market volatility, exchange conditions,
trading halts or any other conditions beyond its control.
TERMINATION
Either Janney or you may terminate this Agreement at any time, effective upon
mailing written notice to the other party. If the Agreement is terminated, you
will continue to be responsible for any obligation incurred by you prior to
termination. Janney reserves the right to reject an account agreement or at any
time to close an account or suspend services provided under this Agreement.

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT
To help the government fight the funding of terrorism and money laundering
activities, federal law requires all financial institutions to obtain, verify, and
record information that identifies each person who opens an account.
What this means for you: When you open an account, we will ask for your name,
address, date of birth and other information that will allow us to identify you.
We may also ask to see your driver’s license or other identifying documents.
You hereby expressly consent to allowing Janney to contact credit bureaus and/
or other third parties to verify the information you have provided on the Client
Agreement.

 

CASH SWEEP PROGRAM
As a convenience to our clients, Janney maintains a cash sweep program
(“Sweep Program”) with three investment options: FDIC Insured Sweep Program
(“Insured Sweep Program”), Dreyfus Money Market Sweep Program (“Dreyfus
Sweep”) and Tax-Advantaged Money Market Sweep Program (“TAMM”). Each
option has certain eligibility requirements which are described in greater detail
below. Janney may change the products available under the Sweep Program
from time to time with notice to you.

You affirmatively consent to participation in Janney’s Sweep Program by signing
the Client Agreement with Janney. However, you may revoke your consent to
participate in the Sweep Program at any time by informing your Financial Advisor
and completing the necessary forms. If you decline participation in the Sweep
Program, the cash portion of your account(s) will remain as a free-credit balance
until you instruct your Financial Advisor to invest such balance. Janney does not
pay interest on free-credit balances in Janney accounts.

The yields and rates of return for deposit accounts in the Insured Sweep Program
are different, and may be lower or higher, than the yields and rates of return
for the money market mutual funds available in Dreyfus Sweep and TAMM. A
discussion of the characteristics and administration of the Sweep Program as
well as a discussion of client rates of return follows below.

You may make a withdrawal from any of the Insured Sweep Program options
on any business day. Withdrawals may be effected through any of the features
available to your account (e.g., check, ATM/debit card) or by contacting your
Financial Advisor.

INSURED SWEEP - GENERAL
Unless the account is an ERISA advisory account or you have selected an
available money market sweep option, you authorize Janney to open a 
sweep account through your eligible Janney account(s) in the Federal Deposit
Insurance Corporation (“FDIC”) insured cash sweep program (“Insured Sweep
Program”). All accounts, other than ERISA advisory accounts, are eligible to
participate in the Insured Sweep Program. Under the Insured Sweep Program,
free credit balances (i.e., cash) in your account as a result of deposits or the
sale of securities are automatically deposited or “swept” into an interestbearing
bank deposit account. Cash deposited in the Insured Sweep Program
accounts at program banks are not subject to market risk and value loss, but
are subject to the risk of a bank’s failure. In the unlikely event that a program
bank fails, the balances in the deposit accounts in the Insured Sweep Program
are insured by the FDIC up to FDIC deposit insurance coverage limits, and are
not covered by Janney or Securities Investor Protection Corporation (“SIPC”).
Under the Insured Sweep Program, your free-credit balances may be deposited
at more than one bank, increasing the potential amount of FDIC insurance
available to you. The Insured Sweep Program provides up to $2.5 million of
FDIC coverage for individual accounts, up to $5 million of FDIC coverage for
joint accounts, up to $2.5 million for certain retirement accounts, and up to
$2.5 million for corporate accounts. You are responsible for monitoring the
total amount of deposits at each Insured Sweep Program bank to determine
the extent of FDIC insurance coverage available to you under this program.
Other deposits, including certificates of deposit, which you maintain directly
with a program bank or through an intermediary (such as Janney or another
broker) in the same capacity will be aggregated with deposits in the Insured
Sweep Program for purposes of calculating the FDIC deposit insurance
coverage limit. A complete list of the banks utilized in the Insured Sweep
Program is located on our website at Janney.com/cash.

The above description of the availability of FDIC insurance for available cash
deposited at the bank(s) is not a comprehensive discussion of the FDIC insurance
rules that may apply to your situation. Additional FDIC information may be
obtained by contacting the FDIC call center at 1-877-ASK-FDIC (1-877-275-
3342, 1-800-925-4618[TDD]), by letter (FDIC, Deposit Insurance Outreach/
Division of Supervision and Consumer Protection, 550 17th Street, N.W.,
Washington, DC 20129-9990), or by accessing the FDIC website at fdic.gov.

INSURED SWEEP - INTEREST RATES
All Accounts, Other Than ERISA Advisory Accounts and Discretionary
Advisory IRA Accounts
Interest rates paid on your cash balances swept under the Insured Sweep
Program are determined daily by Janney based upon a variety of factors
including the interest rate paid by the program banks on the aggregate
balances of the deposit accounts, the fees deducted by Janney out of such
interest rates for certain administrative accounting, recordkeeping and other
services, and prevailing economic and business conditions. Generally, the yields
and rates of return for bank deposit accounts will differ and will be tiered
based on your household balance (see definition of “household” below).
However, eligible advisory accounts will receive the highest interest rate
available at the time of investment regardless of household balance. Interest
accrues and is compounded daily beginning on the day the bank receives
funds from Janney. Accrued interest is credited to your account on the last
business day of the month. If you make a withdrawal, interest will be paid
through the day prior to the day of withdrawal. As referenced above, Janney
is compensated based on the difference or “spread” between the interest rate
paid by the bank on the amounts deposited in the deposit account and the
rates that Janney offers to its clients.

The tier applicable to your household accounts will be determined by Janney on
a monthly basis calculated as of the last business day of the preceding calendar
month. The interest rate tiers are currently as follows:

Interest Rate Tier Total Aggregate Asset Level (of household accounts)
Tier 4 > $1 Million
Tier 3 $500,000 - $999,999
Tier 2 $250,000 - $499,999
Tier 1 < $250,000

The interest rate tiers and tier aggregate assets levels are current as of the date
referenced in the page footer to this Client Agreement but may change over
time with notice to you. Cash balances in new accounts will be placed into Tier 4
through the end of the month in which the account is opened. Thereafter, the cash
balances will earn interest in accordance with the applicable tier level based on the
aggregate value of the assets in your household accounts (minus any liabilities).
For current interest rate tiers and applicable interest rates, go to Janney.com/cash.

Discretionary Advisory IRA Accounts
(All Advisory IRA accounts Other Than Partners Advisory)
The method for calculating the interest rate on cash balances in discretionary
advisory IRA accounts in the Insured Sweep Program is different from
the methodology referenced above. The interest rate on these accounts is
determined by the amount of interest the program banks are willing to pay on
the aggregate balances in the applicable deposit accounts minus the fees paid
to Janney and other parties without regard to household size.

Janney receives a level monthly fee for each discretionary advisory IRA account
in the Insured Sweep Program. This amount is determined based upon a fee
schedule indexed to the Federal Funds Target (FFT) Rate. Janney’s per account
monthly fee is administratively managed to be no less than $0.50 and no more
than $12.00. It is generally anticipated that Janney’s fees will be offset by the
total amounts paid by the program banks. If Janney does not receive sufficient
payments each month from the banks, we reserve the right to debit the account
for the amount of any shortfall.

More information about the Insured Sweep Program, including the interest rate
tiers and yields, is available from your Financial Advisor or by visiting janney.com/
cash.

MONEY MARKET SWEEP: Dreyfus Taxable Money Market Sweep
(“Dreyfus Sweep”) and Tax-Advantaged Money Market Sweep
(“TAMM”)
If you selected one of the money market funds available for your account type
under the Dreyfus Sweep or TAMM, you authorize Janney to open a sweep
account in the designated money market fund.

ERISA advisory accounts that participate in the Sweep Program authorize
Janney to invest available cash balances in the Dreyfus Government Cash
Management Fund - Institutional Shares (DGCXX). The Dreyfus Government
Cash Management Fund is the only Sweep Program option available to ERISA
advisory accounts.

Your deposits in the money market sweep options will earn dividends based
on the interest and income realized by the funds’ underlying investments. The
dividends earned on the shares in the funds will not be payable in cash but will
be reinvested each month in additional shares of the applicable fund at the then
current net asset value. Rates of return you receive on your fund selections will
vary from fund to fund, because such rates are based on the investment made
by the funds net of such fund’s operating expenses. Some funds invest in certain
securities, the income from which is exempt from federal and/or state income
tax. The rates of return on funds will differ from the interest rates available in the
Insured Sweep Program. For a complete list of funds available to your account,
please contact your Financial Advisor.

There is no guarantee that the rate of return or the yields will equal or exceed
rates of return or yields available at other financial institutions or invested in
other products similar to your money market fund sweep option. Yields fluctuate
and past performance is no guarantee of future results. For more information
about the current rate of interest or yield you are receiving in the money market
fund sweep option and current rates of return offered by other cash alternatives,
please go to the Money Market & Margin Rates link available at Janney.com/
cash or contact your Financial Advisor.

Money market mutual funds are registered with the SEC pursuant to the
Investment Company Act of 1940, which imposes special rules on such funds.
Money market mutual funds invest in high quality, short-term securities and seek
to maintain a stable net asset value, but are subject to market risks and potential
loss of value. Prior to or upon investing in a fund you will receive a prospectus
describing the money market fund. You should consider the investment
objectives, risks, charges and expenses of each money market fund
carefully before investing. This and other information is found in the
prospectus or summary prospectus. Assets invested in money market funds
are not held in bank accounts nor are they deposits of, insured or guaranteed by,
the U.S. government, any financial institution, the FDIC or the Federal Reserve
Board. Investments in money market funds are covered by SIPC. Additional
information about SIPC coverage is located at the end of the Client Agreement.

For all funds other than Dreyfus Government Cash Management Fund, Janney
will receive a monthly fee from the money market fund, or its distributor, for
distribution and shareholder services provided by Janney in connection with the
sale of money market funds available under the Dreyfus Sweep and TAMM. The
fee is based on a fixed percentage rate applicable to each fund. These fees paid to
Janney defray the various costs of offering the program to Janney clients, including
those associated with (a) program features, such as the daily sweep arrangement,
purchases, redemptions, dividend reinvestments, and transfers; and (b) money
fund investments, including sub-account, statement preparation and distribution,
distribution of program materials, and responding to investment-related inquiries.

If at any time you change your account from a brokerage account to an advisory
account (other than an ERISA advisory account), you authorize Janney to change
the sweep option for your account to Insured Sweep, as necessary. Additionally,
if at any time you change your account from an advisory account to a brokerage
account, you authorize Janney to change the sweep option for your account to
Insured Sweep, as necessary. Notwithstanding the foregoing, if you transition to
an ERISA advisory account, you authorize Janney to change your sweep option
to the Dreyfus Government Cash Management Fund - Institutional Shares
(DGCXX).

More information about the Sweep Program is available from your Financial
Advisor or by visiting www.janney.com.

HOUSEHOLD/HOUSEHOLD GROUP
Janney households are used to determine the level of benefits and fee waivers
that will be applied to Janney accounts. A household is defined as one or more
accounts with the same mailing address or Social Security/Taxpayer Identification
Number that are serviced by the same Financial Advisor or FA Team. Janney
determines your household balance by aggregating the account balances that
make up the household.

Additionally, a household can be “linked” to another household to receive
certain benefits and fee waivers. The household with the largest asset balance
will set the level of benefits and fee waivers for all accounts in the linked
household group (i.e., balances and fee waivers are not determined by the
combined assets of accounts in all linked households). Households can only
be linked together if the account owners in households to be linked are family
members, defined for this purpose as a grandparent, parent, child, or grandchild.

Janney is not responsible for identifying those eligible accounts that you may
wish to have linked for purposes of determining your household balance. If you
would like Janney to consider accounts to be linked, please notify your Financial
Advisor, who will provide you with more information on linking Janney accounts.
It is your obligation to notify your Financial Advisor of accounts that you would
like to be linked as a household. Janney reserves the right to approve or deny
requests to link accounts and households in its sole discretion.

CHECKWRITING
You may access the value of your Sweep Account with checkwriting privileges
established by Janney at BNY Mellon. Each check is a draft, which is an
authorization to Janney to redeem the amount from your Sweep Account, and
is payable through BNY Mellon. There is no minimum dollar amount for checks
written. Each business day, BNY Mellon will notify Janney of checks written
by you and presented to BNY Mellon for payment. When notified, Janney will
reimburse BNY Mellon for your checks by debiting the Sweep Account. Cancelled
checks will not be returned. You may request copies of specific checks, in which
case a fee will be charged. The combined monthly account statement will list each
check paid, including date written and payee name, and optional expense codes.
In the event a check is presented for an amount in excess of the Sweep Account,
you may be eligible to borrow against margin through your Janney account.
Check with your Financial Advisor for details. Use of the checkwriting service is
subject to applicable fees, including but not limited to, fees for stop payment on
checks, checks returned for insufficient funds, wire transfers and copies of checks.
These fees and charges are subject to change and additional fees and charges
may be added. All fees will be charged to your Janney Advantage® Program.
To place a stop payment on a check, you must call Janney at 1-800-526-6397
and ask for Janney’s Treasury Management Services Department. Allow for a
reasonable time to act on your stop payment order. The stop payment order will
remain in effect for one year. Stop payment orders may be renewed by you each
successive year. Janney reserves the right to restrict the checkwriting privilege on
accounts averaging more than forty (40) checks per month.

FREE CREDIT BALANCES
Janney does not pay interest on free-credit balances in Janney Accounts.
However, if Janney did pay interest on free-credit balances, it would only be
permitted to pay interest on free credit balances arising as a result of securities
trading activities pursuant to federal law and FINRA rules. In the ordinary
course of its business, Janney may use a free credit balance in your account,
subject to the limitations contained in SEC Rule 17 CFR 240.15c3-3. You may
demand and receive from us during normal business hours the delivery of any
free credit balances to which you are entitled, any fully-paid securities to which
you are entitled, or any securities purchased in your margin account upon full
payment of any indebtedness to Janney. Janney may charge you for the delivery
of physical securities to you. Please see Janney’s Schedule of Account Service
Charges at Janney.com for more information about this charge.

ORDER FLOW DISCLOSURE
Janney routes orders for execution to all principal exchanges and particular
broker/dealers or market centers. Janney receives payment for order flow either
in cash payment or in reduced clearing costs at the various exchanges. In all
cases, orders are subject to price improvement from the national best bid or offer
and never are executed at less than the best bid or offer.

PARTIALLY CALLED BONDS
Per FINRA Rule 4340 (Securities Callable in Part), when bonds are called in part
(i.e. – less than the entire amount outstanding is called for redemption), Janney
is required to run an impartial lottery which calls bonds from client accounts on
a randomly selected basis and holds them until the applicable redemption date.
The process by which client accounts are randomly selected can be found on
education/investment-disclosure/partially-called-bond-lottery-process.

MUTUAL FUND TRANSACTIONS
Generally, Janney transacts trades in mutual funds utilizing National Securities
Clearing Corporation’s Fund/SERV system. Most mutual fund business is
transacted by Janney through an omnibus platform, meaning that Janney is
solely responsible for all communications with our clients relating to mutual
fund trades and transaction reporting. Where we conduct mutual fund business
through an omnibus platform, clients have no privileges directly with any mutual
fund company. In such instances, all mutual fund buy and sell orders must be
placed through Janney, all inquiries relating to mutual fund positions must be
directed to Janney, and all transaction confirmations and account statements
relating to mutual fund positions will be issued by Janney. You acknowledge
that Janney will utilize an omnibus platform as the default for most mutual fund
business in your account.

TRADING ON PARITY NOTIFICATION
Under New York Stock Exchange Rules, a specialist is permitted to trade on
parity with orders in the crowd when the specialist is establishing or increasing
his position, so long as floor brokers representing orders in the crowd do not
object to such practice. If you object to a specialist trading on parity with your
order, the specialist would be obligated to honor such a request and refrain from
trading on parity. Unless you inform us otherwise, Janney will handle your orders
as if you have no objections to a specialist trading on parity with your order.

Should you wish to object to this practice for all orders or certain types of orders,
please notify Janney in writing at the following address: Janney Montgomery
Scott LLC, Attn: Capital Markets Compliance, 1717 Arch Street, Philadelphia, PA
19103. If you wish to object to a specialist trading on parity with an individual
order, please inform your Financial Advisor when you place your order.

MARGIN ACCOUNT TERMS
If you have selected margin for your account, the following provisions shall also
govern your Agreement with Janney:

Investing on margin involves the extension of credit to you, and your financial
exposure could exceed the value of securities in your account. By selecting
margin for your account, you acknowledge and agree that you have examined
your financial situation and needs, investment objectives and tolerance for risk,
and have determined that margin financing is suitable and appropriate for you.
You further acknowledge and agree that you have made this determination
independently, and not solely based on the recommendation of Janney. When
you purchase securities on margin, you must provide cash (or acceptable
securities having an equivalent loan value) which is at least sufficient to
comply with the requirements of Regulation T of the Federal Reserve Board.
The difference between the total cost of the purchase and the cash supplied by
you is the amount of Janney’s loan to you, and this is what Janney refers to as
your Debit Balance. It is this Debit Balance upon which interest is charged. Each
additional purchase by you and any charges to your account add to your Debit
Balance. Charges include interest charges and those that may be completely
unrelated to your loan, such as charges made by a Transfer Agent for transferring
your securities, or charges for dividend claims, or interest in a cash account due
to repayment of funds. Adjustment will be made to your Debit Balance for any
balance you may have in a cash account you may keep with us. Interest will not
be paid by Janney on any temporary credit balance which may occur in your
margin account.

Interest is charged against your Debit Balance on a daily basis, and each day’s
charge is accumulated into a monthly total. Janney’s Interest Period will begin
on the Thursday before the last Friday of the prior month and end with the
Wednesday before the last Friday of the current month. Therefore, in verifying
Janney’s interest charge, it is necessary to use your prior month’s statement. The
computation is made as follows:
(1) List the Net Debit Balance in your account and the Rate of Interest on the
first day of the Interest Period.
(2) Note the number of days this Net Debit Balance and the Rate of Interest
remained unchanged.
(3) List each succeeding new Net Debit Balance or each change in the Rate
of Interest and the number of days both the Net Debit Balance and the Rate
of Interest remained unchanged until you have accounted for each day of the
Interest Period.
(4) Finally, to compute the interest charged to your account for the Interest
Period, multiply each Net Debit Balance by the Rate of Interest then in effect and
by a fraction, the numerator of which is the number of days that particular Net
Debit Balance and Rate of Interest remained unchanged, and the denominator
of which is 360. The sum of these products equals the interest charged for this
Interest Period.

Janney’s monthly statement shows (1) the Opening Balance of the Statement
Period, (2) the Closing Balance of the Statement Period, and (3) your Rate of
Interest (or, if there was a change during the month, your Rates of Interest) and
the amounts of interest charged at each Rate. Please note again that to use
these figures to verify the interest charged to your account in any month, you
will need not only the statement for that month but also the statement for the
month preceding it.
Under certain circumstances, interest may be charged on an account even
though the statement does not indicate a Debit Balance. This situation will arise
when the proceeds of a sale have been paid to you prior to the firm’s receipt of
“good delivery” stock. This situation also will arise if you make “good delivery”
prior to settlement date and also accept payment prior to settlement date, in
which case interest will be charged up to the settlement date.

No charges other than those described above will be made to your margin
account as a result of Janney having loaned money to you.

You also acknowledge and agree that the securities purchased on margin are
Janney’s collateral for the loan to you. If the securities in your account decline
in value, so does the value of the collateral supporting your loan. As a result,
Janney can take action, such as issuing a margin call or selling securities or
other assets in any of your accounts held at Janney, in order to maintain the
required equity in your account, except that Janney shall not use assets in an
IRA or ERISA account to satisfy requirements in a non-IRA or non-ERISA account
and vice versa. You understand the following risks associated with the use of
margin in your account: (i) You can lose more funds than you deposit in the
margin account if the value declines; (ii) Janney has the right to force the sale
of securities or other assets in your margin account; (iii) Janney may notify you
of a margin call and allow you a few days to meet the call, but Janney may also
sell your securities without contacting you; (iv) You are not entitled to choose
the securities or other assets that will be liquidated in your account to meet a
margin call; and (v) Janney can increase maintenance margin requirements at
any time and does not have to grant you an extension of time on a margin call.

(A) All transactions between you and Janney shall be subject to the rules
and customs of the market or exchange (and its Clearing House, if any)
where executed. Janney may employ sub-brokers and shall be responsible for
reasonable care in our selection.

(B) All monies, securities, or other property which Janney may at any time
be carrying for you or which may at any time be in Janney’s possession for
any purpose, including safekeeping, shall be subject to a general lien for the
discharge of all your obligations, irrespective of whether or not Janney has
made advances in connection with such securities, or other property, and
irrespective of the number of accounts you hold with Janney. Your monies,
securities, or other property may be carried in Janney’s general 
loans without notice to you and without regard to whether or not
Janney has made advances with respect to such monies, securities
or other property. Except as prohibited under applicable law, securities in
your account may be pledged, re-pledged, hypothecated or re-hypothecated,
separately or in common with other securities or other property. In the event
of your death, your estate shall be liable and each of your heirs, executors,
administrators, representatives, successors and assigns shall continue to be
liable, jointly and severally, to Janney for any Net Debit Balance or loss in your
account in any way resulting from the completion of transactions initiated
prior to the receipt by Janney of the written notice of your death or incurred
in the liquidation of the account or the adjustment of the interests of the
respective parties.

(C) Any liability owed by you to Janney shall be secured by your stocks and/
or securities held by Janney, and Janney is hereby authorized without having
in its possession or subject to its control other stocks and/or securities of the
same kind and amount and without notice to you, to loan and re-pledge the
same (either for the amount due from you or for a greater sum), from time to
time, separately or together with other stocks and/or securities.

(D) You acknowledge that interest Janney may charge may exceed the rate
permitted by the laws of the state in which you reside. You specifically
agree to waive any rights that you might otherwise have under such laws
and consent that the permissible rate of interest is to be governed by the
laws of the Commonwealth of Pennsylvania. Janney may charge monthly, as
interest or otherwise, such sums to compensate it for advances made on your
account at the prevailing and/or allowable rates according to the laws of the
Commonwealth of Pennsylvania, as Janney may determine from the date of
acceptance of this Agreement and thereafter.

(E) If deemed necessary by Janney, in its discretion, for its protection in
connection with the credit Janney has advanced to you, Janney is authorized
to sell any or all of the stocks or securities which may be in its possession,
or which Janney may be carrying for you (either individually or jointly with
others), or to buy in any stocks or other securities, of which your account
may be short, or cancel any outstanding orders in order to close out any
commitment made on your behalf. Such sales and/or purchases may be made
on the exchange or other market where such business is usually transacted or
at public or private sale, without advertising the same. Janney may make such
sale, purchase or cancellation without notice to you and without prior tender,
demand or call of any kind upon you. Janney may purchase the whole or any
part of such stocks or other securities, in whole or in part free from any right
or redemption, in which event you will remain liable for any deficiency.

(F) You agree to maintain the required margin in the account, as established
by Janney from time to time. If there is a decline in the market value of the
stocks and bonds which are the collateral securing the Debit Balance in your
account, it may become necessary for Janney to request additional collateral in
accordance with the rules and regulations of the Financial Industry Regulatory
Authority (“FINRA”) and any other regulatory agency to whose jurisdiction
Janney is subject, and Janney may also, but shall have no obligation to, require
you to deposit such additional collateral as Janney, in its sole discretion,
determines is needed as security for your obligation to Janney. FINRA requires
that a client must maintain equity of 25% in a margin account. (The equity
is the amount by which the market value of the securities in the account
exceeds the Debit Balance.) For a margin account with a good diversification
of investment grade securities, Janney normally requests additional margin
when the equity falls below 30% of the account’s total market value. In
accounts where a single security constitutes most of the collateral, or where
the securities are speculative or low in price, Janney normally requires that the
equity be maintained at 50% or more of the total market value. Irrespective
of these maintenance rates, however, Janney retains the right to require 
additional margin whenever Janney considers it advisable to do so. Margin
calls can be met by delivery to us of cash or of additional acceptable securities.

(G) Janney may at any time terminate all of your accounts and thereupon all
amounts advanced and other balances due, with interest, and commissions shall
be due and payable to Janney.

(H) In the event you sell any security or other property and Janney is unable to
deliver the same to the purchaser by reason of your failure to supply Janney
therewith, then you authorize Janney to borrow any security or other property
necessary to make delivery thereof, and you hereby agree to be responsible
for any loss which Janney may sustain by reason of its inability to borrow the
security or other property sold.

(I) Except as prohibited under applicable law, at any time and from time to
time, in Janney’s discretion, Janney may without notice to you apply and/or
transfer any of your monies, securities and/or other property between any of
your accounts. Any debit occurring in any of your accounts may be transferred by
Janney, at its option, into your margin account.

(J) When placing with Janney any sell order for a short account, you will
designate it as such and you hereby authorize Janney to mark such order as
being “short.” When placing with Janney any order for a long account, you
will designate it as such and you hereby authorize Janney to mark such order
as being “long.” Any sell order that you shall designate as being for a long
account will be for securities then owned by you, and, if such securities are
not then deliverable by Janney from any of your accounts, the placing of such
order shall constitute a representation by you that it is impracticable for you to
deliver such securities to Janney but that you will deliver them as soon as it is
possible for you to do so without undue inconvenience or expense.

(K) In all transactions between you and Janney, you understand that Janney
is acting as your broker, except when Janney discloses to you in writing at or
before the completion of a particular transaction that Janney is acting, with
respect to such transaction, as dealer for its own account or as broker for
some other person.

(L) The following is the annual interest rate that will be charged on Debit
Balances (effective July 1, 2013):

If the Debit Balance is: Percentage of Interest Charged:
Less than $25,000 Janney Base Rate plus 5.875%
Between $25,000 and $49,999 Janney Base Rate plus 5.25%
Between $50,000 and $99,999 Janney Base Rate plus 4.75%
Between $100,000 and $249,999 Janney Base Rate plus 4.25%
Between $250,000 and $499,999 Janney Base Rate plus 4.00%
Between $500,000 and $999,999 Janney Base Rate plus 3.75%
$1,000,000 and above Janney Base Rate plus 3.50%

Janney charges margin interest based on the Janney Base Rate. The Base Rate
is an internally calculated rate established by Janney and changes from time to
time based on Janney’s cost of funds as well as Janney’s assessment of the rates
charged in the financial markets. The interest rate that you will be charged for
borrowing on margin will increase or decrease as the Base Rate increases or
decreases. The Base Rate will be published on Janney’s website and is subject to
change without notice to you.

(M) Until Janney receives written notice of revocation from you, Janney is hereby
authorized to lend, to Janney as a broker/dealer or to others any securities held
by Janney on margin for your account, or under your control. In the event that
your securities have been loaned by Janney on the record date of a shareholder
vote involving those securities, you agree that your vote may be reduced or
eliminated based on the total amount of securities which are being loaned
by Janney. In the event that your securities have been loaned by Janney after
the ex-dividend date, you agree to accept a payment in lieu of a dividend. This 
payment will be reported by Janney as ordinary income, which may cause you to
lose the benefit of preferential tax rates on dividends.

(N) When a short sale is undertaken, the security is borrowed in order to effect
delivery on the settlement date of the trade. From time to time, it is possible,
that as a result of a security being difficult to borrow, a fee may be assessed by
the lender of a stock that the borrower must pay to establish and or maintain
a short position in the security. In these instances, the security is said to be
subject to a negative rebate charge. The amount of the negative rebate charge
is a percentage of the market value of the short position. That a negative rebate
charge is in effect does not remove the possibility that the short position may
be bought back in, with or without prior notification to you. Please note that
Janney may not be in a position to advise you of these charges in advance of the
actual billing cycle that occurs each month. You may, however, ask your Financial
Advisor to find out if a short position is subject to a negative rebate, and if so, at
what rate.

(O) By opening this account, you agree that Janney may obtain credit reports on
each account owner and may report history on this account to consumer credit
reporting agencies.

(P) For purposes of a margin account, all monies, securities and other property
held in an IRA or ERISA account shall not be subject to a general lien for the
discharge of obligations or used as collateral to secure liabilities, obligations
or indebtedness, except to the extent there are liabilities, obligations or
indebtedness owed or incurred with respect to that IRA or ERISA account.

Investment Advisory Agreement
Business Continuation Summary
Margin Disclosure Statement
Account Protection
Electronic Delivery
Privacy Notice