Investment Advisory Services

For Standard & Poor's Investment Advisory Services LLC

Standard & Poor's Investment Advisory Services LLC ("SPIAS") is a registered investment advisor and a wholly owned subsidiary of The McGraw-Hill Companies, Inc.  SPIAS does not provide advice to underlying clients of the firms to which it provides services.  Model portfolios (hereinafter also referred to as "model" or "models") provided by SPIAS are not collective investment funds.  Assets managed in accordance with SPIAS' investment recommendations may lose money.  SPIAS does not act as a "fiduciary" or as an "investment manager", as defined under ERISA, to any investor.  SPIAS is not responsible for client suitability.  Past performance is not indicative of future returns.

Programs and products of the firms to which SPIAS provides services are not endorsed, sold or promoted by SPIAS and its affiliates, and SPIAS and its affiliates make no representation regarding the advisability of investing in those programs and products.  With respect to investment recommendations made by SPIAS, investors should realize that such information is provided only as a general guideline.  SPIAS does not take into account any information about clients, investor or investor's assets when providing its services.  There is not agreement or understanding whatsoever that SPIAS will provide individualized advice to any investor.  SPIAS does not have any discretionary authority or control with respect to purchasing or selling securities or making other investments.  Individual investors should ultimately rely on their own judgment and/or the judgment of a financial advisor in making their investment decisions.

Standard & Poor’s Financial Services LLC, SPIAS, and their affiliates (collectively S&P), and any third-party providers, as well as their directors, officers, shareholders, employees or agents (collectively with S&P, S&P Parties) do not guarantee the accuracy, completeness, adequacy or timeliness of any information, including ratings, and are not responsible for errors and omissions, or for the results obtained from the use of such information, and S&P Parties shall have no liability for any errors, omission, or interruptions therein (negligent or otherwise), regardless of the cause, or for the results obtained from the use of such information. S&P PARTIES DISCLAIM ANY AND ALL EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES OF MERCHANTABILITY, SUITABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE. In no event shall S&P Parties be liable to any party for any direct, indirect, incidental, exemplary, compensatory, punitive, special or consequential damages, costs, expenses, legal fees, or losses (including, without limitation, lost income or lost profits and opportunity costs or losses caused by negligence) in connection with any use of the information contained in this document even if advised of the possibility of such damages.

S&P’s credit ratings are statements of opinion as of the date they are expressed and not statements of fact or recommendations to purchase, hold, or sell any securities or to make any investment decisions. S&P credit ratings should not be relied on when making any investment or other business decision. S&P’s opinions and analyses do not address the suitability of any security. S&P does not act as a fiduciary or an investment advisor, except where registered as such. While S&P has obtained information from sources they believe to be reliable, S&P does not perform an audit and undertakes no duty of due diligence or independent verification of any information it receives.

To the extent that regulatory authorities allow a rating agency to acknowledge in one jurisdiction a rating issued in another jurisdiction for certain regulatory purposes, S&P reserves the right to assign, withdraw or suspend such acknowledgement at any time and in its sole discretion. S&P Parties disclaim any duty whatsoever arising out of the assignment, withdrawal or suspension of an acknowledgment as well as any liability for any damage alleged to have been suffered on account thereof. 

S&P keeps certain activities of its business units separate from each other in order to preserve the independence and objectivity of their respective activities. As a result, certain business units of S&P may have information that is not available to other S&P business units. S&P has established policies and procedures to maintain the confidentiality of certain non-public information received in connection with each analytical process.

S&P may receive compensation for its ratings and certain analyses, normally from issuers or underwriters of securities or from obligors. S&P reserves the right to disseminate its opinions and analyses. S&P's public ratings and analyses are made available on its Web sites, www.standardandpoors.com (free of charge), and www.ratingsdirect.com and www.globalcreditportal.com (subscription), and may be distributed through other means, including via S&P publications and third party redistributors. Additional information about our ratings fees is available at www.standardandpoors.com/usratingsfees.

Based on a universe of funds provided to SPIAS, SPIAS may include in a model portfolio or substitution list, if applicable, otherwise present as an investment option and/or recommend for investment certain funds to which S&P licenses certain intellectual property or otherwise has a financial interest, including exchange-traded funds whose investment objective is to substantially replicate the returns of a proprietary S&P index, such as the S&P 500.  SPIAS includes these funds in models, otherwise presents them as an investment option and/or recommends them for investment based on asset allocation, sector representation, liquidity and other factors; however, SPIAS has a potential conflict of interest with respect to the inclusion of these funds.  In cases where S&P is paid fees that are tied to the amount of assets that are invested in the fund, investment in the fund will generally result in S&P earning compensation in addition to the fees received by SPIAS in connection with its provision of services.  In certain cases there may be alternative funds that are available for investment that will provide investors substantially similar exposure to the asset class or sector.

S&P provides a wide range of services to, or relating to, many organizations, including issuers of securities, investment advisers, broker-dealers, investment banks, other financial institutions and financial intermediaries, and accordingly may receive fees or other economic benefits from those organizations, including organizations whose securities or services they may recommend, rate, include in model portfolios, evaluate or otherwise address.

S&P is not a tax advisor.  A tax advisor should be consulted to evaluate the impact of tax-exempt securities on portfolios and the tax consequences of making any particular investment decision.

SPIAS may consider research and other information from affiliates in making its investment recommendations.  The investment policies of certain model portfolios specifically state that among the information SPIAS will consider in evaluating a security are the credit ratings assigned by S&P.  SPIAS does not consider the ratings assigned by other credit rating agencies.  Credit rating criteria and scales may differ among credit rating agencies.  Ratings assigned by other credit agencies may reflect more or less favorable opinions of creditworthiness than ratings assigned by S&P.

An investment based upon SPIAS' investment recommendations should only be made after consulting with a financial advisor and with an understanding of the risks associated with any investment in securities, including, but not limited to, market risk, currency risk, interest rate risk, political and credit risks, the risk of economic recession and the risk that issuers of securities or general stock market conditions may worsen, over time.  Foreign investing involves certain risks, including currency fluctuations and controls, restrictions on foreign investments, less governmental supervision and regulation, less liquidity and the potential for market volatility and political instability.  As with any investment, investment returns and principal value will fluctuate, so that when redeemed, an investor's shares may be worth more or less than their original cost.

Models that allocate to the following assets classes are subject to additional risks:  (i) Emerging markets and international developing equity investing involves greater risks such as economic and political systems that are less developed, and likely to be less stable, that those of more advanced countries and markets that are characterized by lack of liquidity and price volatility.  (ii) Small Cap and Mid Cap companies entail greater risk that investing in larger, more established ones.  (iii) Real estate investment trusts may be affected by changes in the value of the underlying property, the quality of credit extended, defaults by borrowers and heavy cash flow dependency.  (iv) High yield bonds are lower-rated fixed income securities that may involve greater risk than investments in higher-rated ("investment grade") securities.  (v) Commodities are affected by underlying commodity prices which may exhibit high volatility.  (vi) Mortgage-backed securities have heightened sensitivity to interest rate risk, are subjected to prepayment risk and the resulting uncertainty of the timing of cash flow and are subject to the market's perception of the credit worthiness of the issuer.  (vii) Inflation-protected securities are subjected to several general risks, including interest rate risk, credit risk, market risk, and inflation-protected securities risk.  Interest payments on inflation-protected securities will vary as the principal and/or interest is adjusted for inflation an may be more volatile than interest paid on ordinary fixed income securities.  (viii) Although funds may generally use derivative instruments such as futures contracts and swaps for hedging and risk management, funds in the alternative asset class may use them to a greater extent, which may result in magnified risks.  These instruments are subject to certain risks such as unanticipated changes in securities prices and global currency markets and sudden changes in the liquidity of the market for derivative instruments.  The use of derivatives may also create leveraging risk which may cause greater volatility.  (ix) The price of fixed-income securities fluctuates with charges in interest rates and in response to changes in the financial condition of the issuer.  The value of fixed-income securities generally rises when interest rates fall, and fall when interest rates rise.  (x) Indexing strategy does not attempt to manage volatility, use defensive strategies, or reduce the effects of any long-term periods of poor stock performance.  Market fluctuations can cause the performance of an index to be significantly influenced by a handful of companies.  Performance of a fund or ETF employing an index strategy may sometimes be lower than funds that actively invest in stocks that comprise the index, and as a result, performance may not match that of the index.  Other risks are:  (i) With an actively managed portfolio, the value of a fund's investments could decline because the financial condition of an issuer may change, financial markets may fluctuate or overall prices may decline, or the manager's investment techniques could fail to achieve the fund's investment objective.  (ii) Unforeseen events associated with a company.  (iii) Declines in securities value due to factors affecting markets generally or markets may favor particular kinds of securities or asset classes at different times.  (iv) Stock prices typically fluctuate more than other types of securities and move in cycles with periods or rising and falling stock prices.  (v) Model portfolio returns are also affected by the ability of the underlying fund managers to achieve their investment objectives.  (vi) Stock Baskets tend to be more volatile, have higher betas and sector concentration, or exclude entire sectors, and are sensitive to earnings estimates and their realizations.  (vii) The value of a model's underlying investments could decline because the financial condition of an issuer may change, financial markets may fluctuate or overall prices may decline, or the portfolio officer's investment techniques could fail to achieve the model's investment objective.

For resident of Korea - SPIAS does not act as a "collective investment manager" or "discretionary investment manager" as defined under the Financial Investment Services and Capital Markets Act of Korea ("FSCMA").  This material is distributed to you as a "qualified professional investor" as defined under the FSCMA.

For resident of India - SPIAS is not required to be registered with regulatory authorities in India and hence is not registered with such authorities.

For resident of Australia - SPIAS content and services are distributed by Standard & Poor's Information Services (Australia) Pty Ltd. ("SPIS") in Australia.  This material is distributed to you as a "wholesale client" as defined under the Corporation Act of 2001.  The information in this report has not been prepared for use by retail investors and has been prepared without taking into account of any particular person's financial or investment objectives, financial situation or needs.  Before acting on any advice, any person using the advice should consider its appropriateness having regard to their own or their clients' objectives, financial situation and needs.  You should obtain a Product Disclosure Statement relating to the  product and consider the statement before making any decision or recommendation about whether to acquire the product.  Each opinion must be weighed solely as on factor in any investment decision made by or on behalf of any adviser and any such adviser must accordingly make their own assessment taking into account and individual's particular circumstances.  The Investment Officer may hold the financial product(s) recommendation by SPIAS but SPIAS considers such holdings not to be sufficiently material to compromise the Investment Offficer's recommendations.  An investment Officer's holdings may change at any time.