Client Order Execution Policy

Credit Suisse Securities (USA) LLC Allocation Procedures for Securities Subject to Partial Redemptions or Calls

When an issuer notifies Credit Suisse Securities (USA) LLC ('CSS') that a security is subject to a partial redemption or call, CSSU will determine whether the call or redemption is favorable or unfavorable by comparing the current market price to the call price.

If the call is favorable to the called parties, CSSU will exclude any firm or employee related accounts from the pool of securities eligible to be called, unless and until all other customer securities have been called. If the call is unfavorable, firm and employee accounts are included in the pool of eligible securities to be called.

Once the pool of eligible securities has been determined, CSSU uses a random lottery process to allocate the call/redemption on a fair and impartial basis. The lottery process involves a mathematical formula to identify accounts and quantities of securities that will be allocated the partial call/redemption.

If you have questions regarding the allocation of partial calls/redemptions, please contact your Credit Suisse Representative.

FINRA Rule 5270, effective September 3, 2013, provides that no FINRA member or person associated with a member may cause an order to buy or sell a security or a related financial instrument to be executed when that member has material, non-public information concerning an imminent block transaction in that security, a related financial instrument or a security underlying the related financial instrument prior to the time the information concerning the block transaction has been made publicly available, or has otherwise become stale or obsolete.

In certain instances, Rule 5270 permits members to undertake transactions for the purpose of fulfilling or facilitating the execution of the customer’s block transaction.

Under these certain circumstances, Credit Suisse Securities (USA) LLC (“CSSU”) may use information concerning customer orders or proposed transactions to facilitate the execution of those orders or transactions and may, subject to applicable rules and regulations, take the information into account in limiting the risks to which the CSSU is subject in the course of its activities.

As a result, CSSU may seek to purchase or sell individual or related securities or derivatives to unwind a facilitation position, or to hedge (i.e., reduce or eliminate) its risk in preparing for and executing block orders. CSSU’s activity could potentially have an impact on the prices achieved for the individual securities of your order or transaction; however, CSSU will use reasonable efforts to avoid or minimize any such impact and to obtain the best possible execution for your order or transaction.

If you have any questions, please contact your CSSU representative.

Prohibition Against Trading Ahead of Customer Orders

On September 12, 2011, FINRA adopted Rule 5320, which consolidates the previous customer order protection rules and replaces existing FINRA customer limit and market order protection rules, NYSE Rule 92, and other similar exchange rules.

Rule 5320 generally prohibits a member firm that accepts and holds a customer order from trading a security on the same side of the market for its own account at a price that would satisfy the customer order, unless it immediately executes the customer order up to the size of and at an equal or better price than it traded for its own account. Large orders (10,000 shares or more and $100,000 notional or more) and orders from institutional clients are exempted from Rule 5320. Consistent with existing regulatory guidance, not-held orders are outside of the scope of the rule.

Credit Suisse Securities (USA) LLC ("CSSU") maintains internal controls known as information barriers between its trading units. The information barriers are designed to prevent one trading unit from having knowledge of customer orders held by a different trading unit. With these barriers in place, one trading unit may hold a customer order while another trading unit, including the market making trading unit, executes an order for a Firm account that would satisy the customer order.

If you have any questions, please contact your CSSU representative.

CAPCO has announced that it will no longer be offering insurance coverage to the broker-dealer community and that, as a consequence, it will not renew either the ExcessSIPC Surety Bond or the ExcessFSCS Surety Bond (together, the "Bonds") previously purchased by each of Credit Suisse Securities (USA) LLC ("CSSU") and Credit Suisse Securities (Europe) Limited ("CSSEL") (respectively) when the Bonds expire. Accordingly, on February 16, 2009, the excess insurance coverage available to Customers of CSSU or CSSEL (as the case may be) will expire. For more information, please visit www.capcoexcess.com.

CSSU remains a member of Securities Investor Protection Corporation (SIPC). SIPC plays an important role in the overall system of investor protection in the United States by, in certain specified situations, restoring funds to investors with assets in the hands of bankrupt and otherwise financially troubled brokerage firms. When a brokerage firm is closed due to bankruptcy or other financial difficulties and customer assets are missing, SIPC steps in as quickly as possible and, within certain limits, works to return customers' cash, stock, and other securities.

You may obtain more information about SIPC, including a brochure entitled "How SIPCProtects You, by contacting SIPC" at:

Securities Investor Protection Corporation
805 15th St. NW, Suite 800
Washington, DC 20005-2215
Tel: (202) 371-8300
Fax: (202) 371-6728
Email: asksipc@sipc.org

You may also visit SIPC's website at www.sipc.org. SIPC currently provides $500,000 of net equity protection, including $100,000 for claims for cash awaiting reinvestment (SIPCprotection). SIPC protection applies when a SIPC member firm fails financially and is unable to meet obligations to securities clients, but it does not protect against losses from the rise and fall in the market value of investments and does not cover all assets.

CSSEL is a broker-dealer which is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority in the United Kingdom and is not a member of SIPC.

Contact your Client Service Representative if you have any questions.

1) Private Banking USA customers of CSSU will continue to have a level of excess SIPC coverage after February 16, 2009 by arrangement with Pershing LLC. If you are a Private Banking USA customer, please contact your Private Banking USA relationship manager for further details.

The Financial Services Agency of Japan has tightened controls regarding Short Selling and announced restrictions prohibiting Naked Short Selling effective October 30th, 2008. Consequently, all clients placing short sell orders must have the required borrow arrangement in advance to ensure delivery on settlement date.

This notice is to inform you of the terminology change whereby Credit Suisse shall not be able to accept any Naked Short Sell orders and therefore will be redefining "Short Sell" order as "Short Sell with Locates" order.

Any settlement failure linked to Short Selling will be treated with the highest attention.

We appreciate your full understanding and cooperation to ensure compliance with the new regulation that has been placed on short sell orders.

Rule 204 of Regulation SHO

On July 28, 2009, the Securities and Exchange Commission ("SEC") adopted Rule 204 of Regulation SHO. This Rule extends permanently the requirements of the Rule 204T requiring the delivery of equities sold long or short on settlement date.

What this means for you

In compliance with the terms of the Rule, any fail to deliver position must be closed out by the opening of trading on T+4. While Credit Suisse will use its best efforts to minimize the impact of any fails, we may be required to purchase shares from another source to cover your position should you not deliver the necessary shares by settlement.

Should the fail continue to exist past the opening of trading on T+4, the Rule requires that shares be pre-borrowed prior to Credit Suisse accepting any short sales in that security from any client until the fail to deliver position is closed out. In such case, clients will be required to obtain a pre-borrow from Credit Suisse's Stock Loan Department prior to entering a short sale with us.

Please call your sales representative if you have any questions.

Methodology and Assumption Disclosures

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Only applicable to clients of CSSU

Credit Suisse Securities (USA) LLC and its affiliates (collectively "Credit Suisse") consider you to be an institutional, rather than retail customer. Additionally, services provided to you by Credit Suisse are not intended, nor should they be used, for personal, family, or household purposes. As a result you will not be subject to the protections provided to retail customers under the Securities and Exchange Commission Regulation Best Interest. If you believe you are a retail customer, please contact your Credit Suisse sales representative promptly.