2. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC Polar Investment Counsel Inc 2010 Compliance Meeting Participation of all firm associates is mandatory. Certification of participation is required. Produced by: SWS LLC

3. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting Topics of Discussion Books & Records AML Regulation Overall Supervision The following information is for broker use only and is not to be viewed by anyone other than authorized associates or distributed by any associate of PICI without the explicit approval of Michael C. Jordan – CCO.

4. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting Books & Records Requirements Customer Account Information Complaints The complete section of Rule 3110 can be at: www.finra.org – FINRA Rules www.finra.org

5. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting Books & Records Requirements: Each member shall make and preserve books, accounts, records, memoranda, and correspondence in conformity with all applicable laws, rules, regulations and statements of policy promulgated there under and with the Rules of this Association and as prescribed by SEC Rule 17a-3. The record keeping format, medium, and retention period shall comply with Rule 17a-4 under the Securities Exchange Act of 1934.

6. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting Books & Records Customer Account Information Specific information must be obtained from the client, verified through various methods, approved by authorized individuals, and kept in the strictest confidence. Use of the SWS New Account Module to open accounts is the best way to assure all critical and required information is captured. Step-by-step checks prompt the user for missing information.

7. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting Books & Records Complaints Complaints, whether verbal or written must be reported to the Home Office immediately and documented. FINRA rules require that filings be made within specific time limits.

8. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting AML AML – Definition of Firm’s AML Program OFAC Searches

9. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting AML Definition of: Anti-Money Laundering A set of procedures, laws or regulations designed to stop the practice of generating income through illegal actions. In most cases money launderers hide their actions through a series of steps that make it look like money coming from illegal or unethical sources was earned legitimately.

10. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting AML Firm’s AML Program In review: FinCEN Requests Sharing Information with other Financial Institutions Customer Identification Verification Red Flags Checking OFAC List

11. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting AML OFAC Searches The firm was audited this past year by both the SEC and FINRA. These audits concentrated on the timing of OFAC searches. As a reminder: OFAC searches must be performed and printed PRIOR to an account being opened. The firm also requires searches in an ongoing manner as account situations change.

12. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting Regulation Merge of Regulatory Entities NYSE + NASD = FINRA Fall of Empires Merrill Lynch Bernie Madoff Wachovia Government Intervention GM Takeover Bank bailouts Forced Wall Street mergers

13. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting Overall Supervision With ever increasing rules and regulation, there comes the task of enforcing those rules and regulations. As a result, the firm will be implementing new procedures to try and streamline some of this. More emphasis will be placed on reporting requirements which means keeping track of all that we do. Accountability is the big thing. Are you doing what you say you are doing and how are you doing it??

14. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting In conclusion… Regulation is here to stay What to expect over next year

15. Polar Investment Counsel Inc. Member: FINRA-NFA-MSRB-SIPC 2010 Compliance Meeting Thank you for participating in PICI’s 2010 Compliance Meeting. Home Office 218-681-7344 Be sure to confirm your participation by clicking the submit button at the bottom of the meeting page which will create an email confirmation. This presentation was created for PICI for their use only. Reproduction or use without permission of the writer or producer is strictly prohibited. The views and opinions expressed are not necessarily those of the writer, producer or PICI. Produced by: © SWS LLC 2007