Drystone began operations on 7/1/2008. Christopher H. Jackson is founder and currently sole LLC Member (principal owner) and Manager. *** Drystone is an independent investment counsel, defined as an investment advisory firm offering continuous supervision and management of client investment portfolios and not affiliated with any other firm. Drystone reviews client portfolios on a continuous basis, i.e., throughout the year and on any given day, to reaffirm the appropriateness of each securities position owned and of each overall portfolio profile (asset allocation or mix of asset categories, percentage sizes of different positions, etc.) in the context of each client's written Statement of Investment Objectives (SIO) Snapshot and to reflect Drystone’s most current investment opinions and analysis. Drystone prepares a customized Statement of Investment Objectives (SIO) Snapshot for each client and tailors its management of each client's portfolio to that client's SIO. A client may impose restrictions on investing in certain securities or types of securities by instructing Drystone to include those restrictions in the SIO. *** Drystone does not participate in any "wrap fee" programs. *** Additional information on Drystone’s continuous supervision and management of client investment portfolios and information on Drystone’s use of the terms “Portfolio Counseling” and “Concentrated Investments” follows: Drystone LLC delineates - in its discussions with clients, its client Investment Management Agreement (a.k.a. contract), its written reports, & fees - between two aspects of investment supervisory services: Portfolio Counseling & Concentrated Investments. Portfolio Counseling encompasses all activities related to investment supervision of client portfolios including the following processes: 1) a comprehensive question/answer discussion between Drystone and client about client's financial circumstances and needs for the portfolio and Drystone's projections of securities markets' behavior; 2) a written Statement of Investment Objectives ("SIO") Snapshot for each client portfolio referencing info in Drystone’s files as to client’s financial circumstances, Drystone’s return expectations, risk definition/tolerance, time horizon, spending/liquidity needs, pertinent tax/trust/estate planning context, pertinent client legal or regulatory responsibilities (if any), any unique client considerations (e.g., charitable/personal gifting, client constraints on purchasing specific securities, etc.), and the target asset allocation (% stocks v. % bonds et al.) ranges for that portfolio; 3) continuous screening and analysis of a wide array of securities - including common stocks, exchange-traded funds (ETF's), bonds, etc. - on a number of criteria - including the earnings, cashflow, dividend/interest yields, corporate management quality, industry dynamics, sensitivity to the general business cycle, valuation metrics such as price-earnings ratios or cashflow yields, discounted cashflow (DCF) estimates of intrinsic value, volatility, correlation with other assets, etc. - to assess investment potential and suitability for client portfolios; 4) all purchases, monitoring and sales of securities suitable to/in accordance with each client's SIO and in percentage allocations which balance both the investment attractiveness of each security and its suitability per the client's SIO; 5) periodic reporting of all positions held, transactions made, and total return performance achieved in each client portfolio; 6) updating the SIO Snapshot and portfolio to reflect any changes in client's financial circumstances or portfolio needs or to reflect whether Drystone has met the benchmarks and client expectations articulated in the original SIO. Concentrated Investments is one sub-set or activity within the overall investment supervision of client portfolios. During the screening and analysis of a

wide array of securities (see step 3 previous paragraph), Drystone categorizes certain potential investments as either Diversified Investments or Concentrated Investments and then labels them accordingly in its reports: Diversified Investments draw from asset classes and market sectors which Drystone deems as attractive and appropriate to complete a client's overall portfolio, but where the opportunity for individual security/investment selection to outperform or add significant value above the attractive and appropriate risk-return profile of a low-cost benchmark index vehicle is either too minimal or too uncertain in Drystone's opinion. In these cases, Drystone applies the appropriately thorough level of screening and analysis cited above to identify and then purchase and monitor broad index or diversified buy-and-hold investments in client portfolios. Some examples of Diversified Investments: investment-grade regular and inflation-protected bonds; broadly-diversified index exchange-traded funds (ETF's). Concentrated Investments arise when Drystone perceives a potential opportunity to add a superior risk-return profile or significant value above a benchmark index through further in- depth and intensive analysis and then purchase and monitor for client portfolios of certain specific securities. The additional analysis devoted to Concentrated Investments selection (above and beyond the screening and analysis conducted for Diversified Investments) includes critical reading of corporate 10-K annual reports/SEC filings and proxies, review of competitors and customers, discounted cashflow (DCF) spreadsheet calculations to substantiate valuations, corporate shareholder/analyst conference calls, etc. The term "Concentrated" refers to the additional analysis and selection criteria and the use of a less-diversified allocation to individual securities positions and does not necessarily indicate a more rapid level of portfolio turnover (trading), a shorter time horizon, nor a fundamentally more aggressive or risk-seeking investment philosophy/process than that employed for Diversified Investments. Types of portfolio assets which Drystone may designate as Concentrated Investments include, but may not be limited to: common stocks, American Depositary Receipts/Shares (ADR/ADS), and other individual equity securities. Drystone retains sole discretion to designate the portion of portfolio assets to be described as Concentrated Investments and to apply or remove such designation at any time, but a client and/or Drystone may include targets or guidelines for that portion as a percentage of total portfolio assets in the SIO or other client documentation; Drystone will label the Concentrated Investments portion of portfolio assets as such on the portfolio reports which Drystone prepares and provides to client; and Drystone will communicate to client verbally and/or in writing Drystone’s rationale for designating as Concentrated Investments any types of securities, investment vehicles or portfolio assets other than types specified in this paragraph. The percentages of each portfolio allocated to Diversified Investments and Concentrated Investments will vary over time depending in part on general market conditions and the individual opportunities Drystone perceives as available in the securities markets. Also, for risk management purposes, Drystone and each client explicitly pre-establish a suitable target percentage allocation range for Concentrated Investments in each SIO, i.e., the SIO limits what portion of each portfolio Drystone can direct to securities designated as Concentrated Investments. This helps to address any Drystone conflict of interest and preclude an unsuitable overweighting of Concentrated Investments beyond the level deemed appropriate and prudent per a client's circumstances. *** *Regarding the periodic non-discretionary consultation services mentioned in Form ADV Part