Legal and Compliance

Definitions

Advisor representative

Individuals who have gone through the process of obtaining registration under Williamson Wealth Management, Inc. It is a person who solicits, meets with, communicates or performs advisory services to clients through Blackstone Wealth Management, Inc.

Correspondence

Any communication by letter or electronic mail between client and representative. It is designed for one individual where a representative is responding to a specific client and that client’s needs or wants. Correspondence would include performance reports and quarterly client position reports.

Custody

Holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them.

Disclosure Brochure

The document provided to clients prior to or at the time the client begins advisory services. It is the Form ADV Part II and Schedule F or a document containing, at a minimum, the same information as contained in Part II and Schedule F. Williamson Wealth Management, Inc requires the use of Form ADV Part II and Schedule F. Disclosure Form

Discretionary Account

An account established where the Advisor representative has been granted authority to make investment decisions on behalf of the client without receiving prior authorization. Such authority must be granted in writing. Discretionary authorization must be specifically stated in the advisory agreement or granted to the Advisor representative by a separate limited power of attorney.

Employee Retirement Income Security Act of 1974 (“ERISA”)

A federal statute that established legal guidelines and minimum standards for private pension plan administration and investment practices.

Fiduciary

Anyone responsible for the custody or management of property belonging to others. By definition, regulators deem registered investment advisers to be fiduciaries.

Fiduciary Duty

The highest degree of trust, responsibility and objectiveness required of anyone acting as a fiduciary.

Investment Adviser

Any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or as to the advisability of investing in, purchasing or selling securities or who, for compensation and as part of a regular business, issues or promulgates analysis or reports concerning securities.

Investment Adviser Representative

Any individual who makes any recommendations or otherwise renders advice regarding securities; who manages accounts or portfolios of clients; who determines which recommendation of advice regarding securities should be given; who solicits offers or negotiates for the sale of or sells investment advisory services; or supervises employees who perform any of the foregoing on behalf of a registered investment adviser.

Non-public information

Information that has not yet been effectively communicated to the general public. Information communicated through any form of publication that could be circulated to the general public would not be considered non-public information. To whom has the information been provided? Has the information been communicated to the market place by being published in The Wall Street Journal, brokerage reports, the internet or other publications of general circulation?

Ohio Securities Act

State regulatory statutes governing the registration of securities and licensing of persons transacting business in securities in the State of Ohio, which includes registered investment advisors and their representatives. It also imposes anti-fraud standards in connection with the sale of securities.

Performance Based Fees

An advisory fee based on a share of capital gains or capital appreciation of client assets.

Sales literature

Any written or electronic communication distributed or made generally available to customers or the public, which communication does not meet the criteria of “Advertisement”. Sales literature includes, but is not limited to, circulars, research reports, market letters, performance reports or summaries, form letters, telemarketing scripts, seminar texts and reprints or excerpts of any other advertisement, sales literature or published article. This material is distributed to the public in which there IS audience control.

Soft Dollar Practices

Arrangements under which products or services other than execution of securities transactions are obtained by an adviser from or through a broker/dealer in exchange for the direction of client brokerage transactions to the broker/dealer.