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Outsourcing Your Chief Investment Officer
Comstock’s CIO Services




The following information is of a proprietary nature.
Dissemination to other parties is prohibited without prior
consent of Paul Comstock Partners.

Copyright © 2009 Paul Comstock Partners. All Rights Reserved.
Family Wealth Advisory Services
                                             It’s not only about money… it’s about people.


Family wealth management is complex. It requires experience and sensitivity for the people involved. This fundamental philosophy means that
people are always our primary focus. We at Comstock are in the business of serving individuals, families, family offices, and their philanthropic
entities with financial and investment advisory leadership through an organizational process that engages them in a positive experience. Clients
always remain in charge.

Our Firm
We are a committed team of investment professionals working in partnership with you to enable you to make financial decisions you can trust.
Comstock has provided independent, innovative, investment advisory services to individuals, families, fiduciaries and their advisors for over 25 years.
We are paid only by our clients and do not receive compensation of any kind from money managers. Comstock is wholly owned by its employees.

Why Should We Be Your Strategic Investment Partner?
Paul Comstock Partners is a truly independent and objective firm that provides in-depth strategic investment advice. We are innovative (and
sometimes contrarian), thorough (we conduct our own client-centered research), and have a well-established track record of providing clients with
results that go beyond monetary returns. Our integrity and proven expertise have brought clarity to our clients’ investment decisions and has helped
them to achieve high-quality results.

Recognitions
FIVE STAR: Best in Client Satisfaction Wealth Manager (SM)
Forbes.com - Top 50 Fee-Only Advisors
Fortune - America's Top 50 RIA’s
Trusts & Estates - Registered Rep. Top 100
Investment News - The RIA Giants Top 50




Paul Comstock Partners ®                                                                                                                                  2
Role of CIO

The Chief Investment Officer (CIO) plays a critical role in both the daily investment activities of an individual investor or family wealth
      management entity. The following outlines what you should expect from your CIO:
                   Understand and plan for cash flow requirements
                   Develop risk controls necessary to meet cash flow and growth objectives at a high probability level
                   Organize for successor ownership of portfolio assets
                   Develop a comprehensive investment policy statement
                   Provide extensive due-diligence for ALL available investment opportunities
                   Negotiate terms and costs of engagements for custodianship, transaction execution, and day-to-day management
                   Develop management contract performance review and reporting format
                   Review current investment performance and changes in risk exposures (quarterly)
                   Recommend termination of services providers when performance or changes in the organization warrant such action
                   Introduce and evaluate new management options that compliment or provide a better risk/reward opportunity relative to
                   current management
                   Recommend tactical allocation alterations based on changes in macro and micro economic conditions, investment pricing
                   opportunities, or strategic objectives
                   Coordinate with attorney and CPA on all investment ownership and allocation activities PRIOR to transaction
                   implementation
                   Participate in all strategic planning activities




Paul Comstock Partners ®                                                                                                                      3
Comstock’s 15 Step Process

Our Role: Successful investing must control risk and deliver adequate returns for forward planning, consumption needs, tax
liabilities, and inflation protection. We will provide active investment analytics and advice to construct and implement an investment
program that incorporates the business acumen of the client and the existing portfolio of assets. We seek enhanced returns through
each portfolio choice while incorporating risk reduction.

Present Position Analysis
1.   Determine lifestyle cash flow requirements
2.   Estimate extraordinary uses of cash flow
3.   Inventory assets
4.   Analyze asset allocation expected return/volatility
5.   Review current investment choices
6.   Determine unrealized income tax liabilities for each of the assets
7.   Review fees and expenses applicable to the custody and management of the current assets

Investment Portfolio Development
8.    Establish an asset allocation model that:
               Allows for 3 to 5 years of cash flow requirements without the requirement of selling assets
               Provides a greater than 50% probability of maintaining principal net of inflation/deflation
               Maximizes the return for the price volatility exposure
9.    Select replacement or additional investment choices to provide an enhanced diversification for:
               Portfolio assets
               Non-portfolio assets
10. Review all changes based on net after-tax results

(continued on next page)
Paul Comstock Partners ®                                                                                                                 4
Comstock’s 15 Step Process

11.      Consider the impact of inflation on
               Income requirements now and in the future
               Ability of the portfolio to maintain purchasing power
12.      Review holdings for appropriateness
               Safety of assets from fraud or theft
               Total loss potential
               Costs of each management option and the portfolio as a whole

Investment Portfolio Monitoring
13.   Establish an on-going due-diligence process for each of the delegated management options
              Review compliance with engagement agreements
              Review return/risk results relative to a passive index and peers
14.   Review impact of income taxes
              Fixed income options between taxable and tax-exempt issuers
              Realized and unrealized capital gains and losses
15.   Monitor and control management expenses

Why Is Our Independence So Important?
Comstock was founded on the belief that the best financial advice cannot be delivered to a client if it is tied to a specific financial product or its
compensation is influenced by commission. As a fee-only advisory firm with no conflicts of interest, we are free to examine the entire spectrum of
options and give unbiased opinions based only on our clients’ best interests.



Paul Comstock Partners ®                                                                                                                                 5
Contact Information


Paul Comstock Partners ®
Two Riverway, Suite 1000
Houston, TX 77056

Main (713) 977 2694
Fax (713) 877 1363

New York Satellite Office
1120 Avenue of the Americas, 4th Floor
New York, NY 10036

www.paulcomstockpartners.com

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Independent Investment Advisor

  • 1. Outsourcing Your Chief Investment Officer Comstock’s CIO Services The following information is of a proprietary nature. Dissemination to other parties is prohibited without prior consent of Paul Comstock Partners. Copyright © 2009 Paul Comstock Partners. All Rights Reserved.
  • 2. Family Wealth Advisory Services It’s not only about money… it’s about people. Family wealth management is complex. It requires experience and sensitivity for the people involved. This fundamental philosophy means that people are always our primary focus. We at Comstock are in the business of serving individuals, families, family offices, and their philanthropic entities with financial and investment advisory leadership through an organizational process that engages them in a positive experience. Clients always remain in charge. Our Firm We are a committed team of investment professionals working in partnership with you to enable you to make financial decisions you can trust. Comstock has provided independent, innovative, investment advisory services to individuals, families, fiduciaries and their advisors for over 25 years. We are paid only by our clients and do not receive compensation of any kind from money managers. Comstock is wholly owned by its employees. Why Should We Be Your Strategic Investment Partner? Paul Comstock Partners is a truly independent and objective firm that provides in-depth strategic investment advice. We are innovative (and sometimes contrarian), thorough (we conduct our own client-centered research), and have a well-established track record of providing clients with results that go beyond monetary returns. Our integrity and proven expertise have brought clarity to our clients’ investment decisions and has helped them to achieve high-quality results. Recognitions FIVE STAR: Best in Client Satisfaction Wealth Manager (SM) Forbes.com - Top 50 Fee-Only Advisors Fortune - America's Top 50 RIA’s Trusts & Estates - Registered Rep. Top 100 Investment News - The RIA Giants Top 50 Paul Comstock Partners ® 2
  • 3. Role of CIO The Chief Investment Officer (CIO) plays a critical role in both the daily investment activities of an individual investor or family wealth management entity. The following outlines what you should expect from your CIO: Understand and plan for cash flow requirements Develop risk controls necessary to meet cash flow and growth objectives at a high probability level Organize for successor ownership of portfolio assets Develop a comprehensive investment policy statement Provide extensive due-diligence for ALL available investment opportunities Negotiate terms and costs of engagements for custodianship, transaction execution, and day-to-day management Develop management contract performance review and reporting format Review current investment performance and changes in risk exposures (quarterly) Recommend termination of services providers when performance or changes in the organization warrant such action Introduce and evaluate new management options that compliment or provide a better risk/reward opportunity relative to current management Recommend tactical allocation alterations based on changes in macro and micro economic conditions, investment pricing opportunities, or strategic objectives Coordinate with attorney and CPA on all investment ownership and allocation activities PRIOR to transaction implementation Participate in all strategic planning activities Paul Comstock Partners ® 3
  • 4. Comstock’s 15 Step Process Our Role: Successful investing must control risk and deliver adequate returns for forward planning, consumption needs, tax liabilities, and inflation protection. We will provide active investment analytics and advice to construct and implement an investment program that incorporates the business acumen of the client and the existing portfolio of assets. We seek enhanced returns through each portfolio choice while incorporating risk reduction. Present Position Analysis 1. Determine lifestyle cash flow requirements 2. Estimate extraordinary uses of cash flow 3. Inventory assets 4. Analyze asset allocation expected return/volatility 5. Review current investment choices 6. Determine unrealized income tax liabilities for each of the assets 7. Review fees and expenses applicable to the custody and management of the current assets Investment Portfolio Development 8. Establish an asset allocation model that: Allows for 3 to 5 years of cash flow requirements without the requirement of selling assets Provides a greater than 50% probability of maintaining principal net of inflation/deflation Maximizes the return for the price volatility exposure 9. Select replacement or additional investment choices to provide an enhanced diversification for: Portfolio assets Non-portfolio assets 10. Review all changes based on net after-tax results (continued on next page) Paul Comstock Partners ® 4
  • 5. Comstock’s 15 Step Process 11. Consider the impact of inflation on Income requirements now and in the future Ability of the portfolio to maintain purchasing power 12. Review holdings for appropriateness Safety of assets from fraud or theft Total loss potential Costs of each management option and the portfolio as a whole Investment Portfolio Monitoring 13. Establish an on-going due-diligence process for each of the delegated management options Review compliance with engagement agreements Review return/risk results relative to a passive index and peers 14. Review impact of income taxes Fixed income options between taxable and tax-exempt issuers Realized and unrealized capital gains and losses 15. Monitor and control management expenses Why Is Our Independence So Important? Comstock was founded on the belief that the best financial advice cannot be delivered to a client if it is tied to a specific financial product or its compensation is influenced by commission. As a fee-only advisory firm with no conflicts of interest, we are free to examine the entire spectrum of options and give unbiased opinions based only on our clients’ best interests. Paul Comstock Partners ® 5
  • 6. Contact Information Paul Comstock Partners ® Two Riverway, Suite 1000 Houston, TX 77056 Main (713) 977 2694 Fax (713) 877 1363 New York Satellite Office 1120 Avenue of the Americas, 4th Floor New York, NY 10036 www.paulcomstockpartners.com