AGREED UPON PROCEDURES FOR INVESTMENT ADVISERS

Registered investment advisers with custody over client securities or funds must comply with rules under the Investment Advisers Act of 1940. Note that merely safekeeping client securities and funds at another location such as a bank or trust company does not mean that the adviser is not a custodian.

Complying with these rules is costly and time-consuming. Investment advisers can avoid the constructive custody rules by engaging either an attorney or a certified public accountant to act as an independent representative.

Nardella & Taylor performs such agreed upon procedures for investment advisers.