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1 Uiform Applicatio for Ivestmet Adviser Registratio Part II - Page 1 Name of Ivestmet Adviser: Stephe Craig Schulmerich Address: (Number ad Street) SW Greeburg Rd. Ste 00 (State) (City) Portlad (Zip Code) OR Area Code: OMB APPROVAL OMB Number: Expires: Estimated Average burde hours per respose 9.02 Telephoe Number This part of Form ADV gives iformatio about the ivestmet adviser ad its busiess for the use of cliets. The iformatio has ot bee approved or verified by ay govermet authority. Table of Cotets Item Number Item Page Advisory Services ad Fees 2 Types of Cliets 2 Types of Ivestmets 3 Methods of Aalysis, Sources of Iformatio ad Ivestmet Strategiess 3 Educatio ad Busiess Stadards Educatio ad Busiess Backgroud Other Busiess Activities Other Fiacial Idustry Activities or Affiliatios Participatio or Iterest i Cliet Trasactios 5 10 Coditios for Maagig Accouts 5 11 Review of Accouts 5 12 Ivestmet or Brokerage Discretio 6 13 Additioal Compesatio 6 1 Balace Sheet 6 Cotiuatio Sheet Schedule F Balace Sheet, if required. Schedule G (Schedule A, B, C, D, ad E are icluded with Part I of this Form, for the use of regulatory bodies, ad are ot distributed to cliets) Potetial perso who are to respod to the collectio of iformati cotaied i this form are ot required to respod uless the form displays a curretly valid OMB cotrol umber.

2 Part II - Page 2 Applicat: Stephe Craig Schulmerich 1. A. Advisory Services ad Fees, (check the applicable boxes) For each type of service provided, state the approximate of total advisory billigs from that service. (See istructio below.) Applicat: 100 Provides ivestmet supervisory services Maages ivestmet advisory accouts ot ivolvig ivestmet supervisory services Furishes ivestmet advice through cosultatios ot icluded i either service described above.. () Issues periodicals about securities by subscriptio (5) Issues special reports about securities ot icluded i ay service described above (6) Issues, ot as part of ay service described above, ay charts, graphs, formulas, or other devices which cliets may use to evaluate securities (7) O more tha a occasioal basis, furishes advice to cliets o matters ot ivolvig securities. (8) Provides a timig service. D (9) Furishes advice about securities i ay maer ot described above. (Percetages should be based o applicat's last fiscal year. If applicat has ot completed its first fiscal year, provide estimates of advisory billigs for that year ad state that the percetages are estimates.) B Does the applicat call ay of the services it checked above fiacial plaig or some similar term? I C Applicat offers ivestmet advisory services for: (check all that apply) [J3 A percetage of assets uder maagemet fl () Subscriptio fees [] Hourly charges (5) Commissios Fixed fees (ot icludig subscriptio fees) ] (6) Other D For each checked box i A above, describe o Schedule F: the services provided, icludig the ame of ay publicatio or report issued by the adviser o a subscriptio basis or for a fee applicat's basic fee schedule, how fees are charged ad whether its fees are egotiable whe compesatio is payable, ad if compesatio is payable before service is provided, how a cliet may get a refud or may termiate a ivestmet advisory cotract before its expiratio date 2. Types of Cliets - Applicat geerally provides ivestmet advice to: (check those that apply) pg A. Idividuals R E. Trusts, estates, or charitable orgaizatios PI B. Baks or thrift istitutios 53 F. Corporatios or busiess etities other tha those C. Ivestmet compaies [] G. Other (describe o Schedule F) E3 D- Pesio ad profit sharig plas Aswer all items. Complete ameded pages i full, circle ameded items ad file executio page (page 1).

3 Part II - Page 3 Applicat: Stephe Craig Schulmerich 3. Types of Ivestmets. Applicat offers advice o the followig: (check those that apply) A. Equity Securities 3 exchage-listed securities [3 securities traded over-the-couter [~ foreig issues E3 H. Uited States govermet securities I. Optios cotracts o: r-i r-i J. Optios cotracts o: B. Warrats C. Corporate debt securities (other tha commercial paper) D. Commercial paper securities commodities tagibles itagibles E. Certificates of deposit K. Iterests i parterships ivestig i: real estate oil ad gas iterests other (explai o Schedule F) F. Muicipal securities G. Ivestmet compay securities variable life isurace variable auities mutual fud shares ] L. Other (explai o Schedule F). Methods of Aalysis, Sources of Iformatio, ad Ivestmet Strategies. A. Applicat's security aalysis methods iclude: (check those that apply) Chartig 3 Fudametal () 3 Cyclical (5) Other (explai o Schedule F) Techical B. The mai sources of iformatio applicat uses iclude: (check those that apply) 3 Fiacial ewspapers ad magazies [3 Ispectios of corporate activities (5) PI Timig services (6) [3 Aual reports, prospectuses, filigs with the Securities ad Exchage Commissio () 3 Research materials prepared by others E3 Corporate ratig services (7) Kl Compay press releases (8) Other (explai o Schedule F) C. The ivestmet strategies used to implemet ay ivestmet advice give to cliets iclude: (check those that apply) E3 L g term purchases (securities held at least a year) (5) Margi trasactios 3 Short term purchases (securities sold withi a year) (6) PI Optio writig, icludig covered optios, ucovered optios or spreadig strategies Tradig (securities sold withi 30 days) (7) [] Other (explai o Schedule F) () Short sales Aswer all items. Complete ameded pages i full, circle ameded items ad file executio page (page 1).

4 Part II - Page Applicat: Stephe Craig Schulmerich 5. Educatio ad Busiess Stadards. Are there ay geeral stadards of educatio or busiess experiece that applicat requires of those ivolved i determiig or givig ivestmet advice to cliets? (If yes, describe these stadards o Schedule F.) g<j 6. Educatio ad Busiess Backgroud. For: each member of the ivestmet committee or group that determies geeral ivestmet advice to be give to cliets, or if the applicat has o ivestmet committee or group, each idividual who determies geeral ivestmet advice give to cliets (if more tha five, respod oly for their supervisors) each pricipal executive officer of applicat or each perso with similar status or performig similar fuctios. O Schedule F, give the: ame formal educatio after high school year of birth busiess backgroud for the precedig five years 7. Other Busiess Activities, (check those that apply) rj A. Applicat is actively egaged i a busiess other tha givig ivestmet advice. pi B. Applicat sells products or services other tha ivestmet advice to cliets. [" "I C. The pricipal busiess of applicat or its pricipal executive officers ivolves somethig other tha providig ivestmet advice. (For each checked box describe the other activities, icludig the time spet o them, o Schedule F.) 8. Other Fiacial Idustry Activities or Affiliatios, (check those that apply) r~i A. Applicat is registered (or has a applicatio pedig) as a securities broker-dealer. r-j B. Applicat is registered (or has a applicatio pedig) as a futures commissio merchat, commodity pool operator or commodity tradig adviser. C. Applicat has arragemets that are material to its advisory busiess or its cliets with a related perso who is a: r-\) broker-dealer (7) accoutig firm r-j ivestmet compay (8) law firm [~" other ivestmet adviser (9) isurace compay or agecy r~i () fiacial plaig firm (10) pesio cosultat r~] (5) commodity pool operator, commodity tradig adviser or futures commissio merchat (11) real estate broker or dealer r~ (6) bakig or thrift istitutio (12) etity that creates or packages limited parterships (For each checked box i C, o Schedule F idetify the related perso ad describe the relatioship ad the arragemets.) D. Is applicat or a related perso a geeral parter i ay partership i which cliets are solicited to ivest? (If yes, describe o Schedule F the parterships ad what they ivest i.) Aswer all items. Complete ameded pages i full, circle ameded items ad file executio page (page 1). D

5 Part II - Page 5 Applicat: Stephe Craig Schulmerich 9. Participatio or Iterest i Cliet Trasactios. Applicat or a related perso: (check those that apply) A. As pricipal, buys securities for itself from or sells securities it ows to ay cliet. [""] B. As broker or aget effects securities trasactios for compesatio for ay cliet. C. As broker or aget for ay perso other tha a cliet effects trasactios i which cliet securities are sold to or bought from a brokerage customer. D. Recommeds to cliets that they buy or sell securities or ivestmet products i which the applicat or a related perso has some fiacial iterest. g<3 E. Buys or sells for itself securities that it also recommeds to cliets. (For each box checked, describe o Schedule F whe the applicat or a related perso egages i these trasactios ad what restrictios, iteral procedures, or disclosures are used for coflicts of iterest i those trasactios.) 10. Coditios for Maagig Accouts. Does the applicat provide ivestmet supervisory services, maage ivestmet advisory accouts or hold itself out as providig fiacial plaig or some similarly termed services ad impose a miimum dollar value of assets or other coditios for startig or maitaiig a accout? (If yes, describe o Schedule F.) 11. Review of Accouts. If applicat provides ivestmet supervisory services, maages ivestmet advisory accouts, or holds itself out as providig fiacial plaig or some similarly termed services: A. Describe below the reviews ad reviewers of the accouts. For reviews, iclude their frequecy, differet levels, ad triggerig factors. For reviewers, iclude the umber of reviewers, their titles ad fuctios, istructios they receive from applicat o performig reviews, ad umber of accouts assiged each. Schulmerich & Associates provides a aual review of cliets accout aualy ad will meet with cliets aytime they request. We also offer a retiremet aalysis o a aual basis which is icluded i our maagemet fee. B. Describe below the ature ad frequecy of regular reports to cliets o their accouts. Cliets recieve semi-aual statemets o the performace of the accout for acccout over $100K. Also, cliet recieves a mothly summary of accout from TD Ameritrade. Aswer all items. Complete ameded pages i full, circle ameded items ad file executio page (page 1). g]

6 Part II - Page 6 Applicat: Stephe Craig Schulmerich 12. Ivestmet or Brokerage Discretio. A. Does applicat or ay related perso have authority to determie, without obtaiig specific cliet coset the: () commissio rates paid? g] U3 EjjJ g] C] B. Does applicat or a related perso suggest brokers to cliets? g r~] securities to be bought or sold? amout of the securities to be bought or sold? broker or dealer to be used? For each yes aswer to A describe o Schedule F ay limitatios o the authority. For each yes to A, A() or B, describe o Schedule F the factors cosidered i selectig brokers ad determiig the reasoableess of their commissios. If the value of products, research ad services give to the applicat or a related perso is a factor, describe: the products, research ad services whether cliets may pay commissios higher tha those obtaiable from other brokers i retur for those products ad services whether research is used to service all of applicat's accouts or just those accouts payig for it; ad ay procedures the applicat used durig the last fiscal year to direct cliet trasactios to a particular broker i retur for products ad research services received. 13. Additioal Compesatio. Does the applicat or a related perso have ay arragemets, oral or i writig, where it: (A) is paid cash by or receives some ecoomic beefit (icludig commissios, equipmet or o-research services) from a o-cliet i coectio with givig advice to cliets? (B) directly or idirectly compesates ay perso for cliet referrals? CH D [X] 3 (For each yes, describe the arragemets o Schedule F.) 1. Balace Sheet. Applicat must provide a balace sheet for the most recet fiscal year o Schedule G if applicat: has custody of cliet fuds or securities; or requires prepaymet of more tha $500 i fees per cliet ad 6 or more moths i advace Has applicat provided a Schedule G balace sheet? Aswer all items. Complete ameded pages i full, circle ameded items ad file executio page (page 1). CH C3

SEC Adopts. Amendments. To The Advisers Act Custody Rule SECURITIES LAW ALERT MARCH 2010

SEC Adopts. Amendments. To The Advisers Act Custody Rule SECURITIES LAW ALERT MARCH 2010 MARCH 2010 SEC Adopts Amedmets To The Advisers Act Custody Rule The Securities Exchage Commissio ( SEC ) has adopted amedmets to Rule 206(4)-2 (the Custody Rule ) uder the Ivestmet Advisers Act of 1940