Compliance Memo

Compliance Memorandum 2012-06; Walton International Group

For more information, contact:

Compliance Team

Date Issued:

September 14, 2012

It has come to the attention of GPWM compliance that Walton International Group continues to
be promoted through MGAs to mutual fund representatives who have an approved dual
occupation to sell insurance products.

In light of this, we would like to remind all GPWM Financial Advisors of the MFDA
requirements and GPWM policies in relation to this type of product.
MFDA MR- 0055 reminds Dealers and Financial Advisors that MFDA Rule 1.1.1 requires that
all securities related business be carried out for the account of the Member and through the
facilities of the Member.

As a reminder, GPWM Financial Advisors may only sell approved products and that Walton
International Group products are not approved for sale by GPWM.

We must also remind you of the recent GPWM Compliance Memo on Referral Arrangements
which includes requirements that, prior to any client account opening, GPWM must be made
aware and approve of the referral arrangement, for any paid referral. No such referral
arrangement has been put in place between GPWM and Walton International Group.

As always, if you have any questions or comments, contact the Compliance Department by email at