Customer Account Statement Rule Changes for Direct Participation Programs Taking Effect April, 2016

NASD Rule 2340: General Customer Account Statement Rule THE BASICS

NASD Rule 2340: Statements Must…  Be Issued at Least Quarterly  Describe Securities Held  Show Account Activity Since Last Statement  Provide Balances for Positions

NASD Rule 2340 Main Changes: Providing Balances for Positions 1. Timing of Valuations 2. Methodologies for Valuations 3. Statement Disclosures

NASD Rule 2340 Main Changes: Providing Balances for Positions 1. Timing of Valuations

Timing of Valuations 18 Months After Close Upon Admission of 1st Investor

NASD Rule 2340 Main Changes: Providing Balances for Positions 2. Methodologies for Valuations

OR Methodologies for Valuation Preferred Estimated Value Method 1 Net Investment Method 2 Appraised Value

Method 1 Net Investment Methodology Offering Price Selling Commissions Dealer Manager Fees Organizational and Offering Expenses (estimated from prospectus) Net Investment

Method 2 Appraised Value Methodology Appraisals inclusive of costs and return of capital

NASD Rule 2340 Main Changes: Providing Balances for Positions 3. Statement Disclosures

Statement Disclosures Not Listed on a Securities Exchange Generally Illiquid Sell Price May Not Equal Statement Price

Disclosure for Net Investment Methodology For any Return of Capital (if applicable) IMPORTANT – Part of your distribution includes a return of capital. Any distribution that represents a return of capital reduces the estimated per share value shown on your account statement.

NASD Rule 2340: General Customer Account Statement Rule Summary Earlier Valuations Defined Valuation Methodology: Net Investment or Appraisal Enhanced Disclosures

Customer Account Statement Rule Changes for Direct Participation Programs Taking Effect April, 2016