Client Disclosure Statement

BESTVEST INVESTMENTS, Ltd., hereafter referred to as BESTVEST, is a fully-disclosed Broker Dealer with a history of quality service to the investor. BestVest is a member of the NASD (National Association of Securities Dealers), MSRB. (Municipal Securities Rulemaking Board) and SIPC. (Securities Insurance Protection Corporation).

Anti- Money Laundering Policy

BestVest Investments, Ltd. maintains compliance with the Anti Money Laundering Law commonly known as the Patriot Act. The act provides for criminal penalties for anyone who aids and abets money laundering. To comply with the law, BestVest and/or it's clearing firm screens all accounts for possible past violations and known terrorist lists. BestVest may require additional information from clients to further document your identity. It is necessary for BestVest to have all new account forms filled out in their entirety to help fulfill our responsibility under the act and also to fulfill existing industry regulations for suitability and to know your customer.

Best Execution and Order Flow Disclosure

All orders are executed at prices equal to, or better than, the displayed national best bid/offer prices. Market conditions determine speed and price of transactions. All transactions where executions are at multiple prices, due to lack of liquidity or price improvement, and the subsequent price is averaged may be identified by the abbreviation vwap which stands for value weighted average price. Any client can determine the contra side of any transaction by writing to BestVest Investments Ltd. Our best execution information is available on line at www.mesirowfinancial.com and www.rbcdain.com Our clearing firms create and maintain all information on the websites. BestVest does not guarantee that any or all information on the websites is accurate. BestVest does not receive remuneration in the form of rebates for routing equity securities orders to designated broker dealers or third Markets for execution. This may change without notice. Orders are routed to market centers, including other broker dealers, where, based on experience, they combine price, speed, and size to provide you with what we believe are the best executions.

Fee Disclosure

IRA accounts are assessed an annual fee of $35.00. There is a $75.00 fee for transferring your account to another securities dealer. Inactive full service accounts (accounts which do not do any transactions and have positions in the accounts and are with full service brokers) are subject to a $50.00 inactive fee per year. Securities that are not held in street name are assessed a $20.00 fee per security biannually. These fees offset the cost of maintaining the accounts and are subject to change. Stocks held in street name may be subject to reorganization fees for name changes, mergers, reverse stock splits and tenders. The reorganization fees are generally $25.00 per item but vary according to the transfer agent. Legal fees for changing account name, converting old stock to new stock and processing estate death certificates are $25.00 per item. There is a transaction fee charged by BestVest for purchasing and redeeming mutual fund transactions that might be negated by dealing with the fund directly. Each fund has its own policies and fee schedules. There may be a fee for transferring and shipping individual securities of $15.00 per position. The fee for wiring funds or overnight mail is $20.00 per transaction. Additional fees exist for late payment and late delivery of stock in good deliverable form. Additional fees exist and changes to the fee structure may occur without prior notification.

Settlements

Option trades and U.S. Treasuries settle the next day. Stock transactions settle on the third business day after the trade date. Mutual fund settlement dates can vary from next day to the third day after the trade date. Transactions where payment is made after the settlement date are subject to cancellation in accordance with free-riding regulations. All trades must be paid for in full. To buy and sell securities without paying for them in full or delivering stock is illegal and contrary to securities regulations.

Withholding

If for any reason you sell a security and a signed Taxpayer Identification Number form (which is included in the new account customer agreement or a W-9) is not received by the settlement day, 31% of the proceeds will be withheld. Our clearing firms will not reverse the withholding; the withholding is sent and reported to the IRS as a tax credit for your account and can not be claimed until you file your taxes.

Privacy Statement

BESTVEST does not sell customer proprietary information. Customer information may be shared with our clearing firms and financial institutions such as credit unions and banks in the ordinary course of settling your transactions. Customer information may also be shared with legal and regulatory authorities as required by law or regulation. A separate, complete Privacy Policy Statement is available.

Option Trading

Trading options can be a high risk strategy and no trades will be entered without the client receiving an option disclosure form and sending in additional option paperwork which must be signed by the client, the representative, the branch manager, and an options principal approving the account for options activity.

Margin Trades

No margin trades may be placed before an account is approved for margin trading. Margin trading can be speculative and can result in a client losing more than the original purchase amount. Margin fees vary but are based on the total amount of money borrowed in a margin account. Margin calls may subject clients to buy-ins and sell-outs of their positions without prior notification from BestVest or the Clearing firm. Only experienced knowledgeable investors should have margin accounts. A separate Margin Disclosure Statement is available.

Checks

All checks are to be made payable to Mesirow Financial or RBC Dain who act as our clearing agents for all money and securities. Bounced check fees, ach rejects and insufficient funds fees are $25.00 per item. Checks made payable to "BestVest" will be returned and an interest charge may be incurred due to late payment of securities transactions.

NASD HOTLINE

NASD 1735 K Street, NW Washington DC 20006-1500 202-728-8000 Or WWW.NASD.COM

Phone calls may be recorded by BestVest, Mesirow Financial and RBC Dain. Formal notification is given that any recordings may be used to help with quality assurance. Accounts are insured through SIPC and through additional coverage provided by Mesirow Financial or RBC Dain. The umbrella insurance provides a minimum of $10,000,000 in aggregate security coverage in addition to the SIPC coverage.

Please review this disclosure and all written correspondence from BestVest and Mesirow Financial or RBC Dain carefully.

Written material such as confirmations and statements are deemed to be correct unless BestVest or Mesirow Financial or RBC Dain receive notification of a discrepancy within five days of client's receipt of the material. The Laws of the State of New York will apply to any and all customer inquiries and/or complaints regardless of state of origin.

Any client wishing to receive additional information on policies, fees, and or disclosure statements should contact us at 800-434-1776 or e-mail compliance@bestvest.net or write in care of BestVest Investments, Ltd. 600 North Jackson St., Suite 305 Street, Media, PA 19063.

Thank you for your business!

10/05