Alternative Investment Management of Fund, ETF and Bond Portfolios

disclosures

Web Page Disclosure

The publication of W. Wall & Company, Inc.'s website on the Internet should not be construed by any consumer and/or prospective client as a solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Wall & Co. Global Capital Management's website is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links.

For information pertaining to the registration status of Wall & Co., please contact the SEC or the state securities law administrator for North Carolina. A copy of Wall & Co.'s current written disclosure statement discussing business operations, services, and fees is available from Wall & Co. upon written request. General securities are offered through Ridgeway & Conger, Inc. an FINRA member and SEC registered full-service broker-dealer.

Wall & Co. does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to the Wall & Co. web site or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Certain portions of Wall & Co.'s web site (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, Wall & Co.'s positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from Wall & Co., or from any other investment professional. Wall & Co. staff members are neither attorneys nor accountants, and no portion of the website content should be interpreted as legal, accounting or tax advice.

Performance disclosure

W. Wall & Company, Inc. ("WCI") Global Growth Programs (WGOII) composite performance results represent actual performance results for all corresponding tactical asset allocation model accounts and/or one continuously managed WCI account, which individual account (subject to the limited exceptions noted below) is representative of the performance results achieved by WCI for its program client accounts during the corresponding time period.* The composite performance results reflect the reinvestment of dividends and other account earnings, and are net of applicable account transaction and custodial charges, and the separate fees assessed directly by each unaffiliated mutual fund holding that comprised each portfolio.

Past performance may not be indicative of future results. Therefore, no current or prospective client should assume that future performance will be profitable, or equal either the WCI performance results reflected or any corresponding historical index. For example, the S&P 500 Total Return Index (the "S&P") is a market capitalization-weighted index of 500 widely held stocks often used as a proxy for the stock market. Standard & Poor's chooses the member companies for the S&P based on market size, liquidity, and industry group representation. Included are the common stocks of industrial, financial, utility, and transportation companies. The historical performance results of the S&P (and those of all indices) neither reflect the deduction of transaction and custodial charges, nor the deduction of an investment management fee, the incurrence of which would have the effect of decreasing indicated historical performance results. The historical S&P performance results (and those of all other indices) are provided exclusively for comparison purposes only, so as to provide general comparative information to assist an individual client or prospective client in determining whether the performance of a WCI portfolio performance meets, or continues to meet, his/her investment objective(s). It should not be assumed that WCI account holdings will correspond directly to any such comparative index. Please Note: The WCI performance results do not reflect the impact of taxes. WCI's model investment programs generally involve an above-average turnover, which could negatively impact upon any net after-tax gain experienced by an individual client in a taxable account.

For reasons including variances in portfolio account holdings, variances in the investment management fee incurred, market fluctuation, the date on which a client engaged WCI's investment management services, and any account contributions or withdrawals, the performance of a specific WCI client's account may have varied substantially from the indicated composite model portfolio performance results. In addition, the underlying individual mutual funds that have comprised, and will continue to comprise, the model programs are subject to change at the discretion of WCI. Historical information pertaining to the underlying mutual funds and changes thereto is available from WCI upon request.

In the event that there has been a change in a client's investment objectives or financial situation, he/she/it is encouraged to advise WCI immediately. Different types of investments and/or investment strategies involve varying levels of risk, and there can be no assurance that any specific investment or investment strategy (including the investments purchased and/or investment strategies devised or undertaken by WCI) will be either suitable or profitable for a client's or prospective client's portfolio. Accordingly, no client or prospective client should assume that the above model portfolios (or any component thereof) serve as the receipt of, or a substitute for, personalized advice from WCI, or from any other investment professional.

Information pertaining to WCI's advisory operations, services, and fees is set forth in WCI's current disclosure statement, a copy of which is available from WCI upon request. Information pertaining to any mutual fund that is a current component of a WCI model portfolio is set forth in each respective mutual fund's prospectus, copies of which are available from WCI or directly from the mutual fund company. Performance Results have been audited by MoniResearch Corporation from September 2000 to December 2006, a copy of which audited results is available from WCI upon request. WCI also maintains all information supporting the performance results in accordance with regulatory requirements.

* Prior to 7/1/03, the composite results include the results for three (3) WCI asset allocation programs: IP (International Program), IWP (Invesco World Program) and the WGOII (World Growth Program II). IP and IWP no longer exist, the results for which were merged into the WGOII program. The composite results beginning on 7/1/03 reflect the results for WGOII exclusively.

Privacy Policy

We at Wall & Company Inc. respect your financial privacy. We recognize that you have provided us with private personal financial information, and want you to know our policy regarding that information.

We collect your personal financial information from the following sources:

Information you have given us such as investment advisory agreements, brokerage account applications, and other documents you completed while opening and maintaining your accounts with us.
Information you have given us orally.
Information we receive from third parties such as brokerage firms, outside managers and banks about your transactions with us or with others.

We do not disclose any nonpublic personal financial information about you to anyone, except in the following circumstances:

When we are required to execute transactions for your account or otherwise to provide services you request.
When you have specifically authorized and directed us to do so.
When required by law, such as when our books and records are examined by federal or state regulators.

We prohibit any employee from providing client information over the telephone or in response to an e-mail message unless the employee has identified the other person as the client, a fiduciary representative of the client, an authorized agent of the client or a party that needs the information to complete a transaction for the client (such as broker-dealers, custodians or administrative service providers).

We maintain physical, electronic and procedural safeguards within the firm's offices to protect your privacy.