Investall, Inc..

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of
Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution
Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives
rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number:
2203797
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SHAH, ABBAS, ALI
(For individuals, Last, First, Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for
registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event
occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years
ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 

B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the
event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Revocation
Other Sanctions: 
DISQUALIFICATION FROM REGISTRATION WITH THE CFTC
3.
Date Initiated (MM/DD/YYYY): 
09/01/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CFTC DOCKET NO. SD 09-02
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
LINUXOR ASSET MANAGEMENT LLC
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON DECEMBER 17, 2008, A CONSENT ORDER OF PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF WAS ENTERED AGAINST ABBAS A. SHAH IN CONNECTION WITH A CIVIL
ACTION BROUGHT BY THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") IN THE SOUTHERN DISTRICT OF NEW YORK. THE ORDER SET FORTH ADMITTED FINDINGS OF
FACT AND CONCLUSIONS OF LAW, THAT WHILE AN OWNER AND PRINCIPAL OF LINUXOR ASSET MANAGEMENT LLC, A REGISTERED COMMODITY POOL OPERATOR, SHAH FAILED TO
PROPERLY VALUE THE LINUXOR GLOBAL MACRO FUND, FAILED TO SEND TO FUND PARTICIPANTS REQUIRED QUARTERLY STATEMENTS FOR 2002 TO 2004 AND A TIMELY ANNUAL
REPORT FOR 2002, AND COMMINGLED PARTICIPANTS' FUNDS WITH THE PROPERTY OF OTHERS, IN VIOLATION OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS
THEREUNDER. THIS CONSENT ORDER STIPULATED TO THE FACTS DESCRIBED ABOVE. THE CFTC FILED ITS NOTICE OF ITENNT TO REVOKE REGISTRATION BASED ON THE CONSENT
ORDER, WHICH ORDER WAS GRANTED ON A DEFAULT JUDGMENT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
12/02/2009
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal,
etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition
has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an
advisory affiliate, date paid and if any portion of penalty was waived: 
PERMANENT REVOCATION OF REGISTRATION WITH THE CFTC
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space
provided).
FINAL

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of
Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution
Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives
rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number:
2203797
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SHAH, ABBAS, ALI
(For individuals, Last, First, Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for
registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event
occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years
ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the
event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign

(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NATIONAL FUTURES ASSOCIATION ("NFA")
2.
Principal Sanction:
Revocation
Other Sanctions: 
NEVER AGAIN APPLY FOR NFA MEMBERSHIP OR ASSOCIATE MEMBERSHIP OR ACT AS PRINCIPALS OF AN NFA MEMBER.
3.
Date Initiated (MM/DD/YYYY): 
11/30/2004
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
04-BCC-17
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
LINUXOR ASSET MANAGEMENT LLC
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NFA CASE NO. 04-BCC-017, NOVEMBER 30, 2004: HAVING REVIEWED THE INVESTIGATIVE REPORT SUBMITTED BY THE COMPLIANCE DEPARTMENT OF THE NATIONAL FUTURES
ASSOCIATION ("NFA"), AND HAVING FOUND REASON TO BELIEVE THAT NFA REQUIREMENTS WERE BEING, HAVE BEEN OR ABOUT TO BE VIOLATED AND THAT THE MATTER SHOULD
BE ADJUDICATED, NFA'S BUSINESS CONDUCT COMMITTEE ("BCC") ISSUED A COMPLAINT AGAINST ABBAS A. SHAH. THE NFA ALLEGED THAT SHAH VIOLATED NFA COMPLIANCE
RULES 2-2(C), 2-2(F) AND 2-5. THE NFA ALLEGED THAT SHAH WAS AN NFA ASSOCIATE AND AN ASSOCIATED PERSON ("AP") AND PRINCIPAL OF THE COMMODITY POOL OPERATOR
("CPO") NFA MEMBER. THE NFA ALLEGED THAT SHAH PROVIDED FALSE AND MISLEADING INFORMATION TO FUND PARTICIPANTS AND NFA AND FAILED TO COOPERATE WITH NFA
IN THE COURSE OF AN NFA AUDIT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
03/03/2011
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NEVER AGAIN APPLY FOR NFA MEMBERSHIP OR ASSOCIATE MEMBERSHIP OR ACT AS PRINCIPALS OF AN NFA MEMBER.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal,
etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition
has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an
advisory affiliate, date paid and if any portion of penalty was waived: 
PERMANENT
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space
provided).
ON MARCH 3, 2011, A NATIONAL FUTURES ASSOCIATION ("NFA") HEARING PANEL ("PANEL") ISSUED A DECISION ("DECISION") AS TO LINUXOR ASSET MANAGEMENT LLC AND
ABBAS A. SHAH (COLLECTIVELY, "RESPONDENTS"). SHAH IS THE CHIEF TECHNOLOGIST OF ALLOCATERITE. THE DECISION STATED THAT THE BUSINESS CONDUCT COMMITTEE
("BCC") HAD ISSUED A COMPLAINT AGAINST THE RESPONDENTS. THE BCC ALLEGED THE RESPONDENTS VIOLATED NFA RULES BY SENDING FALSE AND MISLEADING EMAILS,
FAILING TO COOPERATE WITH AN AUDIT, FAILING TO PROPERLY REGISTER AN ENTITY AND DEMONSTRATE A PARTICIPANT WAS A QUALIFIED ELIGIBLE PARTICIPANT, FAILING TO
ISSUE STATEMENTS AND REPORTS. THE DECISION STATED THAT AN OFFER WAS SUBMITTED BY RESPONDENTS IN WHICH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN

THE COMPLAINT, THEY PROPOSED TO SETTLE THE MATTER. PURSUANT TO THE SETTLEMENT OFFER, THE PANEL ORDERED RESPONDENTS TO NEVER AGAIN APPLY FOR NFA
MEMBERSHIP OR ASSOCIATE MEMBERSHIP OR ACT AS PRINCIPALS OF AN NFA MEMBER. THE DECISION DID NOT MAKE ANY FINDINGS THAT RESPONDENTS VIOLATED NFA RULES
AND NO FINES WERE ASSESSED. THE DECISION SETTLED ALL MATTERS BETWEEN RESPONDENTS AND THE NFA; AND BARS ANY FUTURE MEMBER RESPONSIBILITY ACTIONS OR
BCC COMPLAINTS AGAINST RESPONDENTS; AND RESOLVED AND TERMINATED ALL PENDING COMPLAINTS, INVESTIGATIONS AND AUDITS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part 1A or Item 2.F. of Part 1B
of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution
Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated
civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD Number:
2203797
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SHAH, ABBAS, ALI
(For individuals, Last, First, Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for
registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.(1)(a), and only if that
event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten
years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the
event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
COMMODITY FUTURES TRADING COMMISSION
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 

BAR
3.
Filing Date of Court Action (MM/DD/YYYY):
09/19/2005
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Futures - Commodity
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): 
UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, CASE NO. 1:05-CV-08091-LAK
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
LINUXOR ASSET MANAGEMENT LLC
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
ON DECEMBER 17, 2008, A CONSENT ORDER OF PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF WAS ENTERED AGAINST ABBAS A. SHAH IN CONNECTION WITH A CIVIL
ACTION BROUGHT BY THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") IN THE SOUTHERN DISTRICT OF NEW YORK. THE ORDER SET FORTH ADMITTED FINDINGS OF
FACT AND CONCLUSIONS OF LAW, THAT WHILE AN OWNER AND PRINCIPAL OF LINUXOR ASSET MANAGEMENT LLC, A REGISTERED COMMODITY POOL OPERATOR, SHAH FAILED TO
PROPERLY VALUE THE LINUXOR GLOBAL MACRO FUND, FAILED TO SEND TO FUND PARTICIPANTS REQUIRED QUARTERLY STATEMENTS FOR 2002 TO 2004 AND A TIMELY ANNUAL
REPORT FOR 2002, AND COMMINGLED PARTICIPANTS' FUNDS WITH THE PROPERTY OF OTHERS, IN VIOLATION OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Consent
12. Resolution Date (MM/DD/YYYY): 
12/17/2008
 Exact
 Explanation
If not exact, provide explanation:
JUDGE LEWIS KAPLAN OF THE SOUTHERN DISTRICT OF NEW YORL INITIALED ON 12/17/2008; REPRESENTATIVES OF THE COMMODITY FUTURES TRADING COMMISSION INITIALED
ON 12/16/2008; AND ABBAS SHAH, BOTH INDIVIDUALLY AND ON BEHALF OF LINUXOR ASSET MANAGEMENT LLC, AND HIS ATTORNEY INITIALED ON 9/29/2008.
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 200,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal,
etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition
has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement, or monetary compensation, provide total amount, portion levied against you or an
advisory affiliate, date paid and if any portion of penalty was waived:
$200,000 CIVIL PENALTY, A PERMANENT INJUNCTION FROM FUTURE VIOLATIONS OF CERTAIN PROVISIONS OF THE COMMODITY EXCHANGE ACT AND AN INJUNCTION FROM
ENGAGING IN ANY ACTIVITY RELATED TO TRADING IN ANY COMMODITY (AS DEFINED IN SECTION 1A(4) OF THE COMMODITY EXCHANGE ACT)
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space
provided). 
ON DECEMBER 17, 2008, A CONSENT ORDER OF PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF WAS ENTERED AGAINST ABBAS A. SHAH, THE CHIEF TECHNOLOGY
OFFICER OF ALLOCATERITE, INC., IN CONNECTION WITH A CIVIL ACTION BROUGHT BY THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") IN THE SOUTHERN DISTRICT
OF NEW YORK. THE ORDER SET FORTH ADMITTED FINDINGS OF FACT AND CONCLUSIONS OF LAW, THAT WHILE AN OWNER AND PRINCIPAL OF LINUXOR ASSET MANAGEMENT LLC,
A REGISTERED COMMODITY POOL OPERATOR, SHAH FAILED TO PROPERLY VALUE THE LINUXOR GLOBAL MACRO FUND, FAILED TO SEND TO FUND PARTICIPANTS REQUIRED
QUARTERLY STATEMENTS FOR 2002 TO 2004 AND A TIMELY ANNUAL REPORT FOR 2002, AND COMMINGLED PARTICIPANTS' FUNDS WITH THE PROPERTY OF OTHERS, IN VIOLATION
OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, THEREUNDER. THE ORDER IMPOSED A $200,000 CIVIL PENALTY, A PERMANENT INJUNCTION FROM FUTURE
VIOLATIONS OF CERTAIN PROVISIONS OF THE COMMODITY EXCHANGE ACT AND AN INJUNCTION FROM ENGAGING IN ANY ACTIVITY RELATED TO TRADING IN ANY COMMODITY (AS

DEFINED IN SECTION 1A(4) OF THE COMMODITY EXCHANGE ACT). IN HIS ROLE AT ALLOCATERITE, SHAH SERVES AS CHIEF TECHNOLOGY OFFICER AND DOES NOT INTERFACE
WITH ALLOCATERITE'S CLIENTS, ALL OF WHOM ARE THEMSELVES REGISTERED INVESTMENT ADVISERS, EXCEPT AS REQUIRED TO ANSWER QUESTIONS REGARDING THE MODEL
HE CREATED.. SHAH'S ROLE IS TO DEVELOP AND MAINTAIN THE COMPUTER-GENERATED ALGORITHMIC MODEL AND OTHER ALLOCATERITE TECHNOLOGY. IT SHOULD ALSO BE
NOTED THAT ALLOCATERITE DOES NOT MAINTAIN CUSTODY OF ANY CLIENT ASSETS, ONLY INTERFACES WITH ITS INVESTMENT ADVISER CLIENTS (AND NOT WITH THE
UNDERLYING CLIENTS OF THOSE INVESTMENT ADVISORS), AND DOES NOT HAVE ANY DISCRETIONARY FUNCTIONS WITH RESPECT TO CLIENT ASSETS.