Revenue Sharing Policy

The Strategic Financial Alliance, Inc. (“SFA”) offers a wide variety of mutual funds, variable annuities, alternative investments and other securities products to clients. In certain instances, product companies participate in activities that are designed to help facilitate the distribution of their products, such as marketing activities and educational programs, and by offsetting expenses that result from the cost of doing business. In return for assistance in facilitating the activities described above, SFA may receive additional compensation from product sponsors. None of these additional payments is paid to any registered representative who sells these products. These companies may have greater access to our representatives to provide training, education and product information. On request, we will provide our clients a list of product companies currently participating in such programs.

Certain REITs and other non-traded products may re-allow a portion of the dealer manager compensation to SFA (and other broker/dealers) for non-accountable due diligence and marketing expenses. These re-allowances are described in the respective private placement memorandum. If received, no portion of this compensation is paid to any registered representative. Payment, if any, of such re-allowance does not reduce the amount or value of your investment in these products. We will provide the names of these product companies to our clients upon their requests.

For additional information, please contact the Compliance Department at (678) 954-4000 or by e-mail to Compliance@thesfa.net.

Written inquiries may be directed to:

The Strategic Financial Alliance, Inc.

Attn: Compliance Department

2200 Century Parkway, Suite 500

Atlanta, Georgia 30345