4 A. Description of firm, time in business, principal owners. HFG is a full service fiduciary firm, offering expertise in fiduciary oversight for institutional investors, including private, state and local retirement plans, banks and thrifts, charitable organizations, corporations or other business entities, including private investment funds. HFG’s primary business consists of serving as a fiduciary for retirement plans either in a capacity as a Named Investment Fiduciary or as an Independent Fiduciary. Named Investment Fiduciary In its capacity as a Named Investment Fiduciary, HFG will assume complete fiduciary authority for the oversight and management of an ERISA qualified retirement plan Dependent upon the type of plan (defined benefit or defined contribution), HFG’s responsibilities may include, all or any, of the following: development and drafting of a plan’s Investment Policy Statement; determining and implementing an asset allocation plan; selecting, hiring and monitoring of investment managers; hiring and review of third party vendors such as custodians, recordkeepers and administrators; implementation and monitoring of a securities lending program; selection and oversight of plan investment options; and review and approval of plan fees and expenses. Independent Fiduciary The principal of HFG has extensive investment experience and knowledge of the Employee Retirement Income Security Act of 1974 (“ERISA”) and will provide a variety of independent fiduciary services. Often these engagements arise either in order (i) to comply with various rulings or pronouncements issued by the U.S. Department of Labor, or (ii) to structure certain transactions in accordance with ERISA. Independent Fiduciary assignments can take a variety of forms, and among others, include the following: monitoring of company stock accounts, compliance with Prohibited Transaction Exemptions, facilitation of transferring assets between plans, proxy voting, management of stable value programs, litigation settlement, representing the interests of ERISA qualified investors in private investment funds, serving as independent fiduciary of an ESOP, or providing advice regarding, or selection of, retirement income solutions. HFG was established in October 2010 by Mitchell Shames, the firm’s principal owner. Mr. Shames works with both an employee and independent consultants on a project by project basis. Principal Owner Mitchell Shames is a leading expert in fiduciary practices and investment products for domestic and global institutional clients. Until November of 2007, he was the General Counsel for State Street Global Advisors (SSgA), the $2 trillion global investment management unit of State Street Corporation and he was an Executive Vice-President of State Street Corporation. Over the course of his 17 year tenure at SSgA, Mr. Shames (and his staff) structured fiduciary relationships for corporate and institutional clients, ranging from investment management and company stock management to broader fiduciary oversight engagements. He served as a member of SSgA’s Independent Fiduciary Committee that provided fiduciary services for the benefit plans of Enron, United Airlines, Cargill, WR Grace, and other major benefit plan sponsors. His expertise in the establishment of fiduciary policies and procedures contributed to State Street’s victories in significant class action lawsuits, including United Airlines and WR Grace. Based upon his fiduciary expertise, he structured SSgA’s firm-wide Fiduciary Review Committee for purposes of overseeing all fiduciary matters within SSgA. Mr. Shames received an A.B. from the University of Chicago in 1979, a J.D. from Boston College Law School in 1983, and an Ll.M. in taxation from New York University in 1984. 4B. Advisory Services, Specialization HFG will perform a full range of fiduciary services. Named Fiduciary As the Investment Named Fiduciary for a qualified retirement plan, HFG provides a single point of management for an otherwise disaggregated collection of vendors and consultants. HFG will hire and oversee all investment consultants, investment managers including the selection of investment options for a 401(k) plan, providing the plans with the benefit of best industry practices at reasonable and competitive rates. HFG will provide these services across all asset classes including: equities, fixed income and alternative investments. In addition, HFG will, if specifically retained by a client for this non-fiduciary function, review and monitor a plan’s contractual relationships with its trustee, administrator and recordkeeper. At the outset, HFG works with a plan sponsor’s legal advisor to implement a corporate governance structure that clearly allocates fiduciary activities and responsibilities with respect to a retirement plan. This clear delegation and allocation of fiduciary responsibilities is a critical component in enabling officers and directors to mitigate significantly their personal fiduciary liability.

Furthermore, HFG will implement fiduciary policies and procedures consistent with ERISA. On a regular basis, HFG will provide comprehensive professional reports to senior management and/or directors of the plan sponsor. HFG works to understand fully the current state of a retirement plan. HFG carefully reviews the objectives of the plan, the allocation and delegation of responsibilities, vendor relationships and the current communication practices between the investment named fiduciary and company management. With respect to the investment of pension plan assets, HFG reviews the stated plan objectives and prepares suggested revisions, and if necessary, to clarify or adjust the objectives of the plan. HFG believes that the objectives of the plan should be succinct and sharply focused, capturing both the regulatory requirements and the functional objectives of the plan. To develop investment policies and objectives, HFG starts with an assessment of the plan’s actuarial liabilities and funding projections. In addition, HFG evaluates the current economic environment and the outlook for the future. Based on the plan’s existing or revised investment policy, HFG will review and assess the plan’s asset allocation, rebalancing policies and risk control standards. This review will include an analysis of whether the investment assumptions and decisions are consistent with the Investment Policy Statement. With respect to a defined contribution plan, HFG reviews and selects investment options as well as monitoring and approving the fees and expenses of various service providers including recordkeepers, custodians, and administrators. In the event that a defined contribution plan also has a company stock account or a stable value program, HFG will assume the discretionary management of the company stock account or the stable value program. Independent Fiduciary In addition to serving as the Named Investment Fiduciary of a qualified plan, HFG can be retained to provide a specifically designated fiduciary task for a plan. Independent services may include: 1. Assessing, overseeing or managing stable value programs; Overseeing and managing company stock accounts; Directing litigation involving the plan, including approving litigation settlement offers; Assessing, overseeing and managing securities lending programs; Approving plan expenses for service providers; Assessing and monitoring asset pricing and valuation processes; Acting as fiduciary during a transition of assets from one plan to another; Monitoring ERISA prohibited transactions for private investment funds; Serving as the discretionary fiduciary for ESOPs; Acting as a fiduciary and investor representative for private investment funds; Selection, monitoring and oversight of target date fund offerings, including the offering of retirement - income options within defined contribution plans: and Serving as an independent fiduciary for pension de-risking transactions. In such situations, an independent, conflict-free fiduciary would act solely in the best interests of the plan participants. General Statement Other than assignments where HFG assumes discretionary authority over (i) company stock accounts, (ii) stable value programs in which HFG selects wrap contract providers, (iii) private investment funds as an investor representative and fiduciary, or (iii) selection of retirement income products in which guarantee features are imbedded in a target date fund, HFG currently does not exercise discretionary authority over securities. Instead, HFG will manage the selection, oversight and hiring of other investment managers or service providers. 4C. Customized Client Services Clients have the capability contractually to design and limit the services provided by HFG. Through a detailed consultative process, the client and HFG will carefully outline the parameters of HFG’s engagement. Some clients may choose to delegate the full Investment Named Fiduciary responsibility to HFG, while others may retain HFG for a very specific function: such as managing a stable value program (including selection of cash managers and insurance wrap providers). The authority to hire HFG and determine the scope of its services rests at all time with the Client. 4D. Wrap Programs HFG will not participate in any wrap programs. 4E. Client Assets . HFG serves as an Independent Investor Representative and fiduciary for certain ERISA qualified assets in a related group of private investment funds following a direct lending investment strategy. HFG’s role is limited to the resolution of potential conflicts of interest, approval of any investment default provisions in the various fund governing documents, origination of certain term and asset-backed loans if the client’s general partner and manager are prohibited from doing so under ERISA, and providing approval or advice with respect to other matters referred to HFG by the general partner and the manager.