Brokerage and Custodial Services

R.H. Bluestein & Company does not share in the transaction fees or other related charges associated with the purchase and sale of securities. Accordingly, the primary consideration in selecting the brokerage firms with which the Company chooses to transact business is execution capability. Other factors considered are the financial condition of the brokerage firm, their willingness to act as principal to facilitate a transaction, quality of service, depth of research services, and competitiveness of commission rates.

Firms offering specialized research products and services which assist in the investment decision process will be considered. In certain of these circumstances, clients may be expected to pay somewhat higher transaction fees for having received the benefit of such services. On occasion, we will also consider employing various regional and international firms which provide in-depth investment research on corporations indigenous to their geographical region. Also considered are firms offering efficient securities clearing and transferring facilities.

The Company does not act as a custodian of either cash or securities on behalf of its clients. However, we can recommend the facilities of various custodial banks and investment banking firms.