Disclosures

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Form ADV Part II

Pursuant to Rule 204-3 of the Investment Advisers Act of 1940, we continuously offer our clients and prospective clients a copy of our most recent Form ADV Part II describing our firm and methods of operation. Please contact our customer service department @ (888) 743-1400 to request a copy.

1. We collect non-public personal information about our clients from various sources, including applications, or other forms; and information about transactions with our client’s broker-dealers.

2. We do not disclose non-public information about our customers or former customers to anyone, except as permitted by law.

3. We restrict access to non-public personal information to those employees who have a need-to-know in order to provide products or services. We maintain physical, electronic and procedural safeguards to protect non-public personal information.

Investment Commentaries

Commentaries are published by Pentecost Capital Management, Inc. (PCM). They are not purported to be a statement of all material facts relating to any securities that may have been mentioned. The information contained, while not guaranteed as to accuracy or completeness, has been obtained from sources that we believe to be reliable. Any securities mentioned do not represent all securities bought, sold or recommended to PCM clients. Opinions expressed herein are subject to change without notice. PCM, or one or more of its officers, may have a position in any securities discussed herein and may purchase or sell such securities from time to time. Specific information regarding this topic is available any time upon request.

For Our Clients

Notify us as soon as practicable of any material changes in your financial situation, or investment objectives. In addition, let us know if you would like to impose any restrictions on the management of your accounts, or modify any existing account restrictions.

PCM Model Account and Performance Calculations

The PCM model portfolio is an actual PCM client account. It is neither our best performing account, nor our worst. The account typifies PCM’s investment style and is of sufficient size to incorporate all of our current recommendations. The client has not placed any restrictions on the management of the account. Returns across all PCM accounts vary from the performance of our model portfolio for reasons that include, but are not limited to, size, the client’s investment objective, suitability, timing of portfolio reviews and client imposed restrictions.

Performance is the difference, expressed as a percentage, between the beginning value and the ending value of the account, or index, for a single period, adjusted for deposits and withdrawals. Performance of the PCM model portfolio is net of all management fees and commissions.

CAGR is Compound Annual Growth Rate. October 9, 2002 and March 9, 2009 represent low points for the stock market since January 1, 2002.