The following sets forth the policy of Robert Bender & Associates with respect to the protocol to be utilized when adding or deleting a position for every managed account.
1. All accounts maintained at each brokerage will be grouped and traded as a block, when possible. The trader is responsible for verifying the total number of shares held at each brokerage for all accounts managed by Robert Bender & Associates.
2. The blocked accounts can be traded by any of the following methods:
(a) alphabetically by brokerage (A-Z);
(b) alphabetically by brokerage (Z-A);
(c) number of total shares held at each brokerage (from greatest to least);
(d) number of total shares held at each brokerage (from least to greatest);
3. The method utilized should be documented in the trading records and care should be taken to ensure that the next time a position is acquired or deleted, a different trading method is utilized.
If there is any question regarding the above-described procedure, Robert Bender or Reed Bender will make a determination of the method to be utilized based upon a working knowledge of the firm and its trading practices prior to and on the date in question.
Please note that in no event, shall trades made on behalf of the firm personnel or related parties be executed until all outstanding orders for client accounts have been filled.