Q.  Who is Heritage Capital, LLC.?
Heritage Capital, LLC. (hereinafter referred to as Heritage Capital) is an investment management firm registered with the State of Connecticut as a Registered Investment Adviser.

Q.  What is a Registered Investment Adviser?
A Registered Investment Adviser is a fiduciary who has a duty of undivided loyalty to his investment adviser clients and must deal fairly and honestly with them. Any person or entity that holds itself out as a financial planner or investment manager must be registered with the Securities and Exchange Commission or a State Regulatory Body as a Registered Investment Adviser.

Q.  What is Heritage Capital's investment management philosophy?
Heritage Capital's investment management philosophy is focused on capital preservation as well as appreciation through the use of strict risk management strategies designed to protect client assets.

Q.  What makes Heritage Capital unique?
Heritage Capital specializes in an active, top down investment management philosophy for all managed mutual fund, variable annuity and individual equity accounts.

Q.  What is active investment management?
Active investment management is a strategy that seeks to reposition assets as the financial markets change, rather than buy and hold, which exposes assets to undue vulnerability and volatility.

Q.  Why do clients prefer active investment management?
Clients prefer active investment management because their investments are monitored twenty-four hours a day, seven days a week. Additionally, the reduced volatility, vulnerability, and exposure to down markets make their long-term goals more manageable.

Q.  How many investment programs does Heritage Capital offer?
Heritage Capital offers eight investment programs: High Yield Bond, Short-term Gold, Global Asset Allocation, Spectrum, Diversified Growth, Relative Strength Sector, Developed Markets and Emerging Markets. These are non-correlated to each other and largely non-correlated to the U.S. stock market. A primary goal of the firm is to reduce volatility and drawdowns from the various underlying trading instruments.

Q.  How are actively managed investments allocated?
Heritage Capital uses independent, proprietary, computer models for each investment program to determine when risk/reward ratios are most favorable.

Q.  What types of accounts qualify for active investment management?
Individual, corporate, municipal, small business, estate, trusts, and approved retirement plans.

Q.  Are accounts always 100% invested in equities?
No. Heritage Capital's proprietary computer models occasionally identify periods when overall market risk far outweighs potential market reward, at which time assets are moved to the protection of money market funds.

Q.  Where are the actual investments held?
All mutual funds are physically held at each individual fund family. All annuities are held at each individual annuity company. All individual securities are held at an SIPC insured NYSE or NASD clearing firm.

Q.  Are investments locked-in for any period of time?
No. You may liquidate at any time and receive the net asset value of the account, which may be more or less than the original amount invested. Advisory fees already paid are not rebated.

Q.  Is there a minimum initial investment in any of Heritage Capital's investment programs?
Yes, $100,000.00.

Q.  Can additional money be added?
Yes, at anytime.

Q.  Can money be withdrawn at any time?
Yes, at anytime.

Q.  What are the annual costs for Heritage Capital's investment programs?
Heritage Capital charges a maximum 2.5% annual advisory fee based on the total net asset value of the account, at the end of each calendar quarter.

Q.  Are Heritage Capital's fees tax deductible?
Section 212 of the Internal Revenue Code permits an itemized deduction for tax and/or investment advice, subject to certain restrictions.

Q.  Does Heritage Capital provide financial planning, legal services, tax preparation or accounting services?
No. Heritage Capital is an investment adviser. However, upon request, Heritage Capital will refer the names of qualified firms in each field.

Q.  What correspondence will I receive?
At a minimum, you will receive a quarterly statement from the custodian holding your mutual fund, variable annuity, or individual security account. Heritage Capital will forward a quarterly report for each account summarizing the quarterly return and management fees that are due.

Q.  Does Heritage Capital invest in financial products recommended to their clients?
Yes, the principals and affiliated persons of Heritage Capital do invest in products recommended to the client. All investments are made in compliance with trading restrictions and guidelines imposed by the Securities and Exchange Commission.

Q.  Will Client information be kept confidential?
Yes.

Q.  What is the compensation to financial advisers who refer clients from other Registered Investment Advisers?
Heritage Capital shares fees on a fully disclosed basis between 20% and 50% of the gross investment management fee.