Discretionary Management

RS Crum Inc. usually receives discretionary trading authority (via a Limited Power of Attorney) from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. RS Crum Inc. does not contact clients before placing trades in their account, but clients will receive confirmations directly from the broker for any trades placed. Clients grant us discretionary authority in the agreement they sign with us. Clients also give us trading authority over their accounts when they sign the custodian paperwork.

However, certain client-imposed conditions may limit our discretionary authority, such as where the client prohibits transactions in specific security types or industries or directs RS Crum Inc. to execute transactions through specific broker-dealers.

Non-Discretionary Management

For non-discretionary accounts, RS Crum Inc. will contact the client before making recommendations we deem appropriate for the client. Non-discretionary clients should be aware that recommendations are typically time sensitive and the following circumstances may cause market movements to work against the client:

• When we have trading authority, RS Crum will not effect the transaction until we receive verbal or written instructions from the client;
• When we do not have trading authority, the client is responsible for placing the trade;
• RS Crum generally will not aggregate transactions for non-discretionary accounts with discretionary accounts; and
• Transactions for non-discretionary accounts will generally be effected after transactions in discretionary accounts.