PERSHING ORDER PROCEDURE

Given the current market volatility, Pershing would like to take this
opportunity to remind all clients of certain policies and procedures in
connection with the markets and order acceptance and execution for
electronic, non-directed orders sent to Pershing via NetExchange,
NetExchange Services, third party order management systems or FIX.

Order Handling At or Near the Market Open

· Marketable equity orders entered prior to 09:28:00 will, absent
extraordinary circumstances, will be routed to a venue where it will
receive the official opening price for the primary listing market. The
benchmark by primary listing exchange is shown below:

Listing market Benchmark
NYSE NYSE opening price
NYSE ARCA NYSE ARCA opening price
NASDAQ NASDAQ Official Opening Price (NOOP)
ASE NASDAQ Official Opening Price (NOOP)

· For orders entered between 09:28:00 and 09:30:00 EDT (or the time of
the NYSE open if NYSE is the primary listing exchange), Pershing will
attempt to provide the official opening price on a best efforts basis. If
the official opening price cannot be provided, orders will subject be to
execution based on the prevailing market conditions.

· Orders received after 9:30:00 will be routed to the market place in
the normal course and are subject to execution based on the prevailing
market conditions.

· Please be aware that all exchanges have rules that pertain to
"clearly erroneous" transactions. In such cases, executions may have
prices adjusted or may be canceled out right. The declaration of a
“clearly erroneous transaction” is final and binding and cannot be appealed
as stated in the exchange rules.

Circuit Breakers

NYSE Rule 80B (“Trading Halts Due to Extraordinary Market Volatility” or
“Circuit Breakers”) establishes trigger levels for a market-wide trading
halt. The trigger level is based on 10%, 20% and 30% declines of the Dow
Jones Industrial Average (“DJIA”), calculated at the beginning of each
calendar quarter, using the closing value of the DJIA for the prior month.
Each trigger level is rounded to the nearest 50 points.

The Financial Industry Regulatory Authority (“FINRA”) has agreed, upon
request of the Securities and Exchange Commission, to halt domestic trading
in all NASDAQ securities and all equity and equity-related OTC securities
should the NYSE declare a market-wide trading halt, pursuant to NYSE Rule
80B. The Options Exchanges will closely coordinate with the NYSE, as well.

The trigger levels and timeframes for the Fourth Quarter 2008 are as
follows:

1,100-point Decline in the Dow
Before 1:00 p.m. = 1 Hour Halt
1:00 p.m. - 1:59 p.m = 1 Hour Halt
2:00 p.m. - 2:30 p.m. = ½ Hour Halt
After 2:30 p.m = No Effect

2,200-point Decline in the Dow
Before 1:00 p.m. = 2 Hour Halt
1:00 p.m. - 1:59 p.m = 1 Hour Halt
2:00 p.m. - 2:30 p.m. = Close For Day
After 2:30 p.m = Close For Day

3,350-point Decline in the Dow
Before 1:00 p.m. = Close For Day
1:00 p.m. - 1:59 p.m = Close For Day
2:00 p.m. - 2:30 p.m. = Close For Day
After 2:30 p.m = Close For Day

Should the Circuit Breakers be tripped and there is an expectation that the
markets will re-open the same day, Pershing will continue to accept
electronically entered, non-directed orders. Those orders will be routed
to an appropriate market center in anticipation of the re-opening.
Pershing has instructed the market centers to use the same bench mark
opening prices that are used for a normal opening. The exception to this
policy is the NASDAQ NOOP, which currently only permits limit orders to be
included in the re-opening. Market orders may receive the opening price or
be executed in line beginning at the time of the re-open.

Should a Circuit Breaker be tripped which would close the market for the
balance of the day, orders will sent to a pending queue similar to the
process currently in place for orders received after 4:00 p.m. Firms
electing to use the Order Approval process, should review all orders
entered after the halt to determine if the order should be cancelled or
forwarded to the marketplace for the next day’s trading.

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IMPORTANT: Any information contained in this communication is intended for the use of the named individual or entity. All information contained in this communication is not intended or construed as an offer, solicitation, or a recommendation to purchase any security. Advice, suggestions or views presented in this communication are not necessarily those of Pershing LLC nor do they warrant a complete or accurate statement.

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