There are two important steps in becoming a client of CastleMoore Inc. First is the exploration phase; second, the decision.

CastleMoore is in the business of managing people's life savings. We can manage all of it or part of it, subject to our minimum accounts size of $300,000. We are not stock brokers, financial planners, mutual funds salesmen or insurance salesmen.

You AND CastleMoore need to have a handle on your personal investment needs. What is your experience as an investor? What level of risk/reward is suitable for you? CastleMoore offers four levels of service:

Saver Accounts
We use this service to compete with banks, trust companies and insurance companies for investors who are not interested in the stock market. We invest in long term bonds when interest rates are going down and shorter term maturities when interest rates are going up. Our goal is to make capital gain as well as just interest. Ordinary portfolio managers refer to this approach as "the fixed income portion."

Class Accounts
We use this service to compete with financial planners and other mutual funds salesmen. These accounts invest in the bond market and in domestic and foreign stock markets when they are in up trends. We do not invest in them when they are in down trends.

Focus Accounts
We use this service to compete with stock brokers. When the overall stock market is in an up trend, we focus our holdings on the strongest industries and avoid the weaker ones. Of course, when the overall market is in a down trend, we avoid it all together.

Two-Way Accounts
We use this service to compete with more sophisticated stock brokers and hedge funds. The goal is to make capital gain in both rising markets and falling markets. Not for everyone.

We offer serious shoppers a free CD that explains these different investors in more detail. You can listen to the CD on line or in your car. See the Next Steps section.

We use a detailed questionnaire to help you and CastleMoore decide what is the best way for you to invest. Normally we gather this information in a personal meeting between you and our Executive Client Liaisons. Where this is difficult, we do it online. All information that is submitted is reviewed in person or by telephone with an Advising representative staff member. This information will enable us to make you a proposal using our proprietary BluePrint™ investment policy statement. Our proposal will take into account the regulatory and fiduciary responsibilities that are involved in the discretionary management of investments in Canada. It will take into account your investment wants and needs and our investment skills. If everything matches, we will invite you to do business on the basis of the BluePrint™.

The Decision triggers action: we fill in the paperwork and transfer your investment account to CastleMoore. Our service agents will do this for you.

Future Changes: We are working on two additional projects so that we may provide a broader level of service to investors.

Accounts Under $100,000 - Mutual Fund Family
For investors who can't afford the full service we are creating a CastleMoore family of mutual funds.

Accounts $100,000 to $1 Million - Pooled Accounts (SMA's)
Separate accounts invested in the CastleMoore pools - stock, bond & currency pools - a lower cost way in investing in the same securities as our larger accounts.

Accounts Over $1 Million - Separately Managed Accounts (SMA's)
The service we currently offer all our clients. All positions are held individually and managed on your behalf.

STATEMENT OF POLICIES AND PROCEDURES TO ENSURE FAIRNESS IN THE ALLOCATION OF INVESTMENT OPPORTUNITIES AMONG CLIENTS

Each client of the Firm shall be sent a copy of this Policy Statement, a copy of which is (or will be) filed with Ontario Securities Commission, and posted to the Firm web site
(http://www.castlemoore.com/fairnesspolicy).

Fairness Policy Statement
This Policy Statement covers the relationships between CastleMoore Inc. and its clients, those for whom the Firm provides discretionary management services (“discretionary clients”) and those who purchase advice-for-fee (“advisory clients”). It may be amended as necessary, without prejudice to existing clients, to accommodate future expansion in the scope of CastleMoore Inc. business activities.

Allocation:
According the CastleMoore business model, discretionary clients are categorized according to their investor characteristics and risk tolerance, as determined by the Firm’s proprietary methodology. Accounts of a given category are aggregated as though a single account. Thus, investment opportunities are evaluated with respect to suitability to particular “aggregate” accounts. When a long position is created or augmented, the shares accumulated are distributed to individual accounts on a pro-rata basis, based on account size. Individual accounts are simultaneously debited for the shares acquired (for equities), at the weighted average cost per share of the entire accumulation for that trading day.

The same principles apply for the sale from accounts of security positions, except that pro-rata allocations are made based on market values of the security being sold rather than on the entire portfolio, thus avoiding the potential of creating unwanted short positions.

Thus, all individual accounts within the foregoing classification scheme pay or receive the same price per share, subject to rounding.

The following is a partial list of potential deviations from CastleMoore’s general policy on the allocation of investment opportunities:

1. An individual account should have adequate cash or margin to accommodate new positions purchased.
2. Client preferences are honoured to the best of CastleMoore ability. For example, a client may have an aversion to ownership in tobacco or defence contractor companies, and would thus be excluded from an investment opportunity in these areas.
3. CastleMoore is party to an agreement with National Bank Correspondent Network (“NBCN”) providing for custodial and trading services to CastleMoore clients. New clients to the Firm, however, are free to maintain their investment accounts at any dealer they chose. By electing to maintain accounts outside the CastleMoore/NBCN relationship, they commit their assets to the trading service to those firms, likely achieving different results.CastleMoore applies the same standard of fairness to all clients notwithstanding the choice of custodian/trading desk, but cannot guarantee the same execution price across all investment firms.
4. Client accounts received by CastleMoore from other institutions, or otherwise inherited by CastleMoore, and which include pre-existing security positions, are considered to be “in transit” (i.e. in the process of being converted over to the Firm's proprietary management model) and may be excluded from aggregation even when received in their entirety. For instance, an account may arrive at CastleMoore already holding a position in a security being evaluated by CastleMoore's managers (or a security with similar investment characteristics, such that a swap would not create significant value-added to the portfolio) . This account would therefore not participate in a subsequent decision to buy the featured security.
5. Only accounts or portions of accounts for which CastleMoore has discretionary power are aggregated.
6. Accounts whose mandates differ from CastleMoore's general mandate may be managed differently, although with equal fairness, than those which more readily lend themselves to CastleMoore's general management style. Examples include a mutual fund that invests in transportation stocks or a client group that is loyal to a particular sub-advisor employed by the Firm.
7. Orders may be only partially filled (pro rata) within the desired range, and accounts may be selected at random for complete or full fills if a pro rata filling results in insignificant allocations such that there is essentially no effect or nominal effect on portfolio performance.
8. New issues are allocated on the same basis as secondary ones, with the exception that clients who chose to house their accounts at dealers other than NBCN may receive a greater or lesser allocation that would have otherwise been the case. Notwithstanding, accounts held by employees of the Firm or by the Firm itself are subject to internal review to insure that they do not benefit from favourable new issue allocations, wherever such accounts are hosted. Allocations which too small to be meaningful if spread over more than a small number of suitable accounts are so distributed by random selection.
9. A security sale in a particular account may be deferred if the financial benefit from the sale would be outweighed by its tax consequence at the time of sale.

Commissions:
CastleMoore’s arrangement with NBCN are inclusive of trading commissions (subject to certain maximums), as are, by extension, the fees paid to CastleMoore by its clients whose accounts reside with NBCN. Thus, for the majority of the Firm’s client base, the allocation of commission is not applicable. Clients opting to host accounts elsewhere are subject to commissions charge by those firms. To the extent that those commissions are negotiable, however, CastleMoore uses best efforts to minimize them.

For a PDF version of CastleMoore's Fairness Policy, please email: info@castlemoore.com

All costs including trading, tax & performance reporting, registered account fees, and advisory are detailed below. The scale is a sliding schedule such that as total assets under CastleMoore administration cross each new category the overall management cost is reduced by the "new" blended rate. There's no extra fees or anything hidden. There are a couple nuisance charges which are flow through costs to us and they are listed at the bottom of the page.

For example an account size of $750,000 would allow for 2.00% on the first $500,000 and 1.60% on the next $250,000, for a total blended rate of 1.87%.

All accounts under management are billed individually. However, a client may request that all fees be combined and charged to a specific account in order to take advantage of certain tax strategies.

For clients preferring to have their account managed with their own discount brokerage or investment dealer, CastleMoore will provide managerial service at a rate of 1.25% of assets under management. Accordingly, investors are responsible for separate commission and account fees with their brokerage firm.

Additional costs for clients who custody their accounts with NBCN:

Please ensure that you check with your custodial broker, if not NBCN, for the costs of similar charges.

Please take a moment to fill out this Investment Questionnaire that will allow us to create an IPS (Blueprint) and label prospects with the appropriate portfolio. Upon receiving your Investment Questionnaire we will send you partner Ken Norquay's CD entitled "The 5 Levels of Investor Consciousness"

Investment Questionnaire