January 2012 Attention: Head Traders, Trading Desk Personnel, and Compliance Officers From: ConvergEx Group Broker-Dealers

including ConvergEx Execution Solutions LLC, ConvergEx Limited, G-Trade Services LLC, ConvergEx Prime Services LLC (formally known as NorthPoint Trading Partners LLC), and ConvergEx Asia Pacific Limited Re: Not Held or Working Orders; Agency, Riskless Principal and Net Trading As part of our annual disclosures, the ConvergEx Group broker-dealers listed above would like to remind you about how we generally handle your orders. We encourage you to read the account agreement previously sent to you for more information and disclosures governing your account with us. ConvergEx is a leading technology company providing products and services to asset managers and financial intermediaries globally. Our products and services span the investment life cycle and center on the development, marketing and servicing of technology-based solutions that enable customers to achieve improved investment results through operational and workflow efficiencies, execution and analytical tools and highly personalized service. One area of specialization is providing a full array of leading technologies and an integrated platform of performance driven, global execution capabilities. As such, you can send orders to a ConvergEx Group broker-dealer by one or more of the following methods: (1) via FIX connection from the Eze OMSTM, an awardwinning order management system provided by ConvergEx Group; (2) via FIX from the RealTick EMS, an award-winning execution management system provided by ConvergEx Group; (3) via FIX connection from virtually any other execution or order management system, including LiquidPoints BLAZE, HEAT and DerivatEx; or (4) via direct communications (such as email, IM, fax, telephone) with one of our execution desks. Of course, once we receive your order, we try to handle it in accordance with our understanding of your business and the particular instructions associated with that order. However, our brokerdealers understand that our customers want us to treat every order,1 no matter how we receive it, as a not held or working order. This means that you grant us latitude in how we seek to achieve best execution on your behalf, including the ability, under FINRA Rule 5320, to execute other trades at any price without being required to execute your order at the same price, regardless of whether the order is handled by one of our algorithms, by our smart order routing technology (including our advanced DMA TactEx tools), in VortEx, MillenniumSM, ConvergEx CrossSM or NXP, or by a member of one of our execution desks using one or more of those technologies. For more
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The only exception is orders marked immediate or cancel (IOC) or held.

information about our investment technologies and investment services, please click on this link, www.convergex.com, or contact your ConvergEx Group coverage person. By using not held orders, you tap into the expertise and analysis of our technologies and people, and allow both to take into consideration a wide variety of factors, such as the characteristics of your order (e.g., size, number of securities), liquidity of the security and market impact, desire for anonymity, and other relevant factors. Our order handling procedures also allow us to execute your orders (or orders for other customers against whom we match your orders) on an agency, riskless principal or net basis. Essentially, this means we (or our affiliates) are compensated in different ways, depending on the trade: (i) an explicit commission on each transaction (when we trade on an agency basis); or (ii) a spread or commission equivalent imbedded in the cost of each transaction (when we trade on a riskless principal or net basis). With respect to certain orders, one of our broker-dealers may act as agent and route the trade to an affiliate for execution, clearing or settlement. In these cases, the affiliate may act as agent or on a riskless principal or net basis (at a price inclusive of their mark-up/down, commission equivalent or spread) and earn its own compensation (including, but not limited to, payment for order flow). Your reported price will include such affiliates compensation and such affiliates compensation will be in addition to any reported commission. Our affiliates compensation may be based on either a fixed fee or may be calculated as a percentage of the amount by which the affiliates executions exceed a benchmark. Neither we nor our affiliates engage in market making, investment banking or at risk proprietary trading. We and our affiliates may, in the ordinary course of businesses, receive remuneration from each other and third parties in connection with transactions, such as payment for order flow. We are happy to discuss with you the capacity in which we (and/or our affiliates) may act (and, accordingly, the method by which we and/or our affiliates will be paid), so you know in advance with respect to any particular transaction. Of course, the contra side to your trade may have a different arrangement with us. We believe net trading provides our customers with access to greater liquidity, especially because many of our financial intermediary customers strongly prefer that we trade with them on a net basis. By utilizing our execution technologies and capabilities and our access to markets around the world, we always seek to obtain best execution for our customers. ConvergEx Group will continue to develop new technologies and trading strategies to meet your liquidity needs. But no matter how much technology we give you, our customer service is paramount. The ConvergEx Group broker-dealers will continue to execute your orders in accordance with our normal order handling procedures, including as described in this letter. You may notify us in writing that you do not wish your orders to be treated in this fashion by sending a letter or email to: Robert Virgilio, Chief Compliance Officer, ConvergEx Group, 1633 Broadway, 48th Floor, New York, New York 10019; rvirgilio@convergex.com. And you can always contact your coverage person on an order by order basis to request a held order or an agency-only execution.