Common use of Advertising and Sales Literature Review Clause in Contracts

Advertising and Sales Literature Review. a. ALPS shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS by Sponsor, as well as certain related consultative services. b. ALPS’ services are based on the understanding that Sponsor will utilize current systems and expertise owned by ALPS, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS will base its reviews on: (i) the guidelines contained within ALPS’ Sales and Advertising Guide and ALPS’ Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS will be provided by ALPS to Sponsor with comments or approval no later than three business days after receipt in AdLit. c. Each marketing piece submitted to ALPS for review will be subject to the following process: a) Each piece will undergo review at ALPS by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPS; b) ALPS’ comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS reviewer, will be consistent with the guidelines specified by ALPS in Section 1.b., or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein; d) ALPS will make all required FINRA filings of marketing materials which have been approved by ALPS. d. If Sponsor wishes ALPS to perform an expedited review of marketing pieces within one business day of ALPS’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS cannot guarantee a one business day review for these items. b) The marketing piece must be submitted via ALPS’ AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ensure that ALPS has a full one business day to review and provide Sponsor with comments. c) Sponsor must check the box on the AdLit coversheet whereby Sponsor requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS is notified of the expedited request. ALPS cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS will review and submit comments to Sponsor within this timeframe.

Advertising and Sales Literature Review. a. ALPS (i) The Distributor shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS Distributor by SponsorS2K. Documentation (which shall include electronic correspondence) not defined as “marketing pieces,” which shall include, as well as certain related consultative services.but is not limited to, correspondence and materials provided directly in response to due diligence requests, shall be principally reviewed and approved by S2K. b. ALPS’ (ii) Distributor’s services are based on the understanding that Sponsor S2K will utilize current systems and expertise owned by ALPSDistributor, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS Distributor will base its reviews on: (i) the guidelines contained within ALPS’ Distributor’s Sales and Advertising Guide and ALPS’ Distributor’s Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) SEC related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ Distributor’s submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS Distributor will be provided by ALPS Distributor to Sponsor S2K with comments or approval no later than three business days after receipt in AdLit. c. (iii) Each marketing piece submitted to ALPS Distributor for review will be subject to the following process: a) Each piece will undergo review at ALPS Distributor by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPSDistributor; b) ALPS’ Distributor’s comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS Distributor reviewer, will be consistent with the guidelines specified by ALPS Distributor in Section 1.b.2(b)(ii) above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS Distributor will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein;; and d) ALPS Distributor will make all required FINRA filings of marketing materials which have been approved by ALPSDistributor. d. (iv) If Sponsor S2K wishes ALPS Distributor to perform an expedited review of marketing pieces within one business day of ALPSDistributor’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) A charge of $250 will apply to each request for expedited review, in addition to FINRA filing fees. b) The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS Distributor cannot guarantee a one business day review for these items. bc) The marketing piece must be submitted via ALPS’ Distributor’s AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ) on a business day in order to ensure that ALPS the Distributor has a full one business day to review and provide Sponsor S2K with commentscomments within such one business day timeframe. cd) Sponsor S2K must check the box on the AdLit coversheet whereby Sponsor S2K requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS Distributor is notified of the expedited request. ALPS . e) Distributor cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS Distributor will review and submit comments to Sponsor S2K within this timeframe. If Distributor fails to provide S2K with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ALPS (i) The Distributor shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS Distributor by SponsorNorthStar. Documentation (which shall include electronic correspondence) not defined as “marketing pieces,” which shall include, as well as certain related consultative servicesbut is not limited to, correspondence and materials provided directly in response to due diligence requests, shall be principally reviewed and approved by Northstar. b. ALPS’ (ii) Distributor’s services are based on the understanding that Sponsor NorthStar will utilize current systems and expertise owned by ALPSDistributor, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS Distributor will base its reviews on: (i) the guidelines contained within ALPS’ Distributor’s Sales and Advertising Guide and ALPS’ Distributor’s Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) SEC related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ Distributor’s submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS Distributor will be provided by ALPS Distributor to Sponsor NorthStar with comments or approval no later than three business days after receipt in AdLit. c. (iii) Each marketing piece submitted to ALPS Distributor for review will be subject to the following process: a) Each piece will undergo review at ALPS Distributor by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPSDistributor; b) ALPS’ Distributor’s comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS Distributor reviewer, will be consistent with the guidelines specified by ALPS Distributor in Section 1.b.2(b)(ii) above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS Distributor will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein;; and d) ALPS Distributor will make all required FINRA filings of marketing materials which have been approved by ALPSDistributor. d. (iv) If Sponsor NorthStar wishes ALPS Distributor to perform an expedited review of marketing pieces within one business day of ALPSDistributor’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) A charge of $250 will apply to each request for expedited review, in addition to FINRA filing fees. b) The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS Distributor cannot guarantee a one business day review for these items. bc) The marketing piece must be submitted via ALPS’ Distributor’s AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ) on a business day in order to ensure that ALPS the Distributor has a full one business day to review and provide Sponsor NorthStar with commentscomments within such one business day timeframe. cd) Sponsor NorthStar must check the box on the AdLit coversheet whereby Sponsor NorthStar requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS Distributor is notified of the expedited request. ALPS . e) Distributor cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS Distributor will review and submit comments to Sponsor NorthStar within this timeframe. If Distributor fails to provide NorthStar with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ALPS (i) The Distributor shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS Distributor by Sponsor, as well as certain related consultative servicesBluerock. b. ALPS’ (ii) Distributor’s services are based on the understanding that Sponsor Bluerock will utilize current systems and expertise owned by ALPSDistributor, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS Distributor will base its reviews on: (i) the guidelines contained within ALPS’ Distributor’s Sales and Advertising Guide and ALPS’ Distributor’s Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ Distributor’s submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS Distributor will be provided by ALPS Distributor to Sponsor Bluerock with comments or approval no later than three business days after receipt in AdLit. c. (iii) Each marketing piece submitted to ALPS Distributor for review will be subject to the following process: a) Each piece will undergo review at ALPS Distributor by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPSDistributor; b) ALPS’ Distributor’s comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS Distributor reviewer, will be consistent with the guidelines specified by ALPS Distributor in Section 1.b.2(b)(ii) above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS Distributor will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein; d) ALPS Distributor will make all required FINRA filings of marketing materials which have been approved by ALPSDistributor. d. (iv) If Sponsor Bluerock wishes ALPS Distributor to perform an expedited review of marketing pieces within one business day of ALPSDistributor’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) A charge of $250 will apply to each request for expedited review, in addition to FINRA billing costs. b) The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS Distributor cannot guarantee a one business day review for these items. bc) The marketing piece must be submitted via ALPSDistributor’ AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ensure that ALPS Distributor has a full one business day to review and provide Sponsor Bluerock with comments. cd) Sponsor Bluerock must check the box on the AdLit coversheet whereby Sponsor Bluerock requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS Distributor is notified of the expedited request. ALPS . e) Distributor cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS Distributor will review and submit comments to Sponsor Bluerock within this timeframe. If Distributor fails to provide Bluerock with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ALPS shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS by SponsorClient, as well as certain related consultative services. b. ALPS’ services are based on the understanding that Sponsor Client will utilize current systems and expertise owned by ALPS, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS will base its reviews on: (i) the guidelines contained within ALPS’ Sales and Advertising Guide and ALPS’ Written Supervisory Procedures; (ii) rules and guidance issued by FINRA the Financial Industry Regulatory Authority (“FINRA”) and the Securities and Exchange Commission (the “SEC”) related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS will be provided by ALPS to Sponsor Client with comments or approval no later than three (3) business days after receipt in AdLit. c. Each marketing piece submitted to ALPS for review will be subject to the following process: a(i) Each piece will undergo review at ALPS by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPS; b(ii) ALPS’ comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS ALPS’ reviewer, will be consistent with the guidelines specified by ALPS in Section 1.b.. herein, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c(iii) ALPS will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein;; and d(iv) ALPS will make all required FINRA filings of marketing materials which have been approved by ALPS. d. If Sponsor Client wishes ALPS to perform an expedited review of marketing pieces within one business day of ALPS’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a(i) The a charge of $250 will apply to each request for expedited review, in addition to FINRA billing costs; (ii) the marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS cannot guarantee a one business day review for these items.; b(iii) The the marketing piece must be submitted via ALPS’ AdLit system by no later than 3:00 P.M. p.m. Mountain Time (2:00 P.M. PT/5:00 P.M. ETp.m. Pacific Time /5:00 p.m. Eastern Time). This will ensure that ALPS has a full one business day to review and provide Sponsor Client with comments.; and c(iv) Sponsor Client must check the box on the AdLit coversheet whereby Sponsor Client requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS is notified of the expedited request. ALPS cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS will review and submit comments to Sponsor Client within this timeframe. If ALPS fails to provide Client with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ALPS (i) The Distributor shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS Distributor by SponsorNorthStar. Documentation (which shall include electronic correspondence) not defined as “marketing pieces,” which shall include, as well as certain related consultative servicesbut is not limited to, correspondence and materials provided directly in response to due diligence requests, shall be principally reviewed and approved by NorthStar. b. ALPS’ (ii) Distributor’s services are based on the understanding that Sponsor NorthStar will utilize current systems and expertise owned by ALPSDistributor, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS Distributor will base its reviews on: (i) the guidelines contained within ALPS’ Distributor’s Sales and Advertising Guide and ALPS’ Distributor’s Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) SEC related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ Distributor’s submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS Distributor will be provided by ALPS Distributor to Sponsor NorthStar with comments or approval no later than three business days after receipt in AdLit. c. (iii) Each marketing piece submitted to ALPS Distributor for review will be subject to the following process: a) Each piece will undergo review at ALPS Distributor by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPSDistributor; b) ALPS’ Distributor’s comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS Distributor reviewer, will be consistent with the guidelines specified by ALPS Distributor in Section 1.b.2(b)(ii) above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS Distributor will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein;; and d) ALPS Distributor will make all required FINRA filings of marketing materials which have been approved by ALPSDistributor. d. (iv) If Sponsor NorthStar wishes ALPS Distributor to perform an expedited review of marketing pieces within one business day of ALPSDistributor’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) A charge of $250 will apply to each request for expedited review, in addition to FINRA filing fees. b) The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS Distributor cannot guarantee a one business day review for these items. bc) The marketing piece must be submitted via ALPS’ Distributor’s AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ) on a business day in order to ensure that ALPS the Distributor has a full one business day to review and provide Sponsor NorthStar with commentscomments within such one business day timeframe. cd) Sponsor NorthStar must check the box on the AdLit coversheet whereby Sponsor NorthStar requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS Distributor is notified of the expedited request. ALPS . e) Distributor cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS Distributor will review and submit comments to Sponsor NorthStar within this timeframe. If Distributor fails to provide NorthStar with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ALPS (i) The Distributor shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS Distributor by Sponsor, as well as certain related consultative servicesSC. b. ALPS’ (ii) Distributor’s services are based on the understanding that Sponsor SC will utilize current systems and expertise owned by ALPSDistributor, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS Distributor will base its reviews on: (i) the guidelines contained within ALPS’ Distributor’s Sales and Advertising Guide and ALPS’ Distributor’s Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ Distributor’s submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS Distributor will be provided by ALPS Distributor to Sponsor SC with comments or approval no later than three business days after receipt in AdLit. c. (iii) Each marketing piece submitted to ALPS Distributor for review will be subject to the following process: a) Each piece will undergo review at ALPS Distributor by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPSDistributor; b) ALPS’ Distributor’s comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS Distributor reviewer, will be consistent with the guidelines specified by ALPS Distributor in Section 1.b.2(b)(ii) above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS Distributor will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein; d) ALPS Distributor will make all required FINRA filings of marketing materials which have been approved by ALPSDistributor. d. (iv) If Sponsor SC wishes ALPS Distributor to perform an expedited review of marketing pieces within one business day of ALPSDistributor’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) A charge of $250 will apply to each request for expedited review, in addition to FINRA billing costs. b) The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS Distributor cannot guarantee a one business day review for these items. bc) The marketing piece must be submitted via ALPSDistributor’ AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ensure that ALPS Distributor has a full one business day to review and provide Sponsor SC with comments. cd) Sponsor SC must check the box on the AdLit coversheet whereby Sponsor SC requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS Distributor is notified of the expedited request. ALPS . e) Distributor cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS Distributor will review and submit comments to Sponsor SC within this timeframe. If Distributor fails to provide SC with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ALPS shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS by Sponsor, as well as certain related consultative services. b. . • ALPS’ services are based on the understanding that Sponsor will utilize current systems and expertise owned by ALPS, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS will base its reviews on: (i) the guidelines contained within ALPS’ Sales and Advertising Guide and ALPS’ Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) SEC related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS will be provided by ALPS to Sponsor with comments or approval no later than three business days after receipt in AdLit. c. . • Each marketing piece submitted to ALPS for review will be subject to the following process: a) : • Each piece will undergo review at ALPS by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPS; b) ; • ALPS’ comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS reviewer, will be consistent with the guidelines specified by ALPS in Section 1.b.above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) . • ALPS will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein; d) . • ALPS will make all required FINRA filings of marketing materials which have been approved by ALPS. d. . • If Sponsor wishes ALPS to perform an expedited review of marketing pieces within one business day of ALPS’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) : • A charge of $250 will apply to each request for expedited review, in addition to FINRA billing costs. • The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS cannot guarantee a one business day review for these items. b) . • The marketing piece must be submitted via ALPS’ AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ensure that ALPS has a full one business day to review and provide Sponsor with comments. c) . • Sponsor must check the box on the AdLit coversheet whereby Sponsor requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS is notified of the expedited request. ALPS cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS will review and submit comments to Sponsor within this timeframe. If ALPS fails to provide Sponsor with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ○ ALPS shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS by Sponsor, as well as certain related consultative services. b. . ○ ALPS’ services are based on the understanding that Sponsor will utilize current systems and expertise owned by ALPS, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS will base its reviews on: (i) the guidelines contained within ALPS’ Sales and Advertising Guide and ALPS’ Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) SEC related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS will be provided by ALPS to Sponsor with comments or approval no later than three business days after receipt in AdLit. c. . ○ Each marketing piece submitted to ALPS for review will be subject to the following process: a) : ▪ Each piece will undergo review at ALPS by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPS; b) ; ▪ ALPS’ comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS reviewer, will be consistent with the guidelines specified by ALPS in Section 1.b.above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) . ▪ ALPS will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein; d) . ▪ ALPS will make all required file the Sales Materials with FINRA filings of marketing materials which have been approved only if it is considered necessary. If asked by ALPS. d. the Sponsor, ALPS will provide the requisite information with respect to the such filing requirements with FINRA. ○ If Sponsor wishes ALPS to perform an expedited review of marketing pieces within one business day of ALPS’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) : ▪ The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS cannot guarantee a one business day review for these items. b) . ▪ The marketing piece must be submitted via ALPS’ AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ensure that ALPS has a full one business day to review and provide Sponsor with comments. c) . ▪ Sponsor must check the box on the AdLit coversheet whereby Sponsor requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS is notified of the expedited request. ALPS cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS will review and submit comments to Sponsor within this timeframe.

Advertising and Sales Literature Review. a. ALPS (i) The Distributor shall provide review of broker-dealer or RIA related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS Distributor by Sponsor, as well as certain related consultative servicesCION. b. ALPS’ (ii) Distributor’s services are based on the understanding that Sponsor CION will utilize current systems and expertise owned by ALPSDistributor, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS Distributor will base its reviews on: (i) the guidelines contained within ALPS’ Distributor’s Sales and Advertising Guide and ALPS’ Distributor’s Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) SEC related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ Distributor’s submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS Distributor will be provided by ALPS Distributor to Sponsor CION with comments or approval no later than three business days after receipt in AdLit. c. (iii) Each marketing piece submitted to ALPS Distributor for review will be subject to the following process: a) Each piece will undergo review at ALPS Distributor by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPSDistributor; b) ALPS’ Distributor’s comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS Distributor reviewer, will be consistent with the guidelines specified by ALPS Distributor in Section 1.b.2(b)(ii) above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS Distributor will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein; d) ALPS Distributor will make all required FINRA filings of marketing materials which have been approved by ALPSDistributor. d. (iv) If Sponsor CION wishes ALPS Distributor to perform an expedited review of marketing pieces within one business day of ALPSDistributor’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) A charge of $250 will apply to each request for expedited review, in addition to FINRA billing costs. b) The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS Distributor cannot guarantee a one business day review for these items. bc) The marketing piece must be submitted via ALPS’ Distributor’s AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ensure that ALPS Distributor has a full one business day to review and provide Sponsor CION with comments. cd) Sponsor CION must check the box on the AdLit coversheet whereby Sponsor CION requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS Distributor is notified of the expedited request. ALPS . e) Distributor cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLitAdLit from CION. ALPS Distributor will review and submit comments to Sponsor CION within this timeframe. If Distributor fails to provide CION with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ALPS (i) The Distributor shall provide review of broker-dealer related advertising and sales literature pieces (“marketing pieces”) submitted to ALPS Distributor by Sponsor, as well as certain related consultative servicesSC. b. ALPS’ (ii) Distributor’s services are based on the understanding that Sponsor SC will utilize current systems and expertise owned by ALPSDistributor, specifically the AdLit Advertising Review System (“AdLit”), and that ALPS Distributor will base its reviews on: (i) the guidelines contained within ALPS’ Distributor’s Sales and Advertising Guide and ALPS’ Distributor’s Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ Distributor’s submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS Distributor will be provided by ALPS Distributor to Sponsor SC with comments or approval no later than three business days after receipt in AdLit. c. (iii) Each marketing piece submitted to ALPS Distributor for review will be subject to the following process: a) Each piece will undergo review at ALPS Distributor by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece submitted to ALPSDistributor; b) ALPS’ Distributor’s comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS Distributor reviewer, will be consistent with the guidelines specified by ALPS Distributor in Section 1.b.2(b)(ii) above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS Distributor will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece submitted via the process described herein; d) ALPS Distributor will make all required FINRA filings of marketing materials which have been approved by ALPSDistributor; and e) Copies of all correspondence and communications with FINRA will be available to SC via Distributor's AdLit system. d. (iv) If Sponsor SC wishes ALPS Distributor to perform an expedited review of marketing pieces within one business day of ALPSDistributor’ receipt of such marketing pieces, the expedited review will be performed subject to and in accordance with the following: a) A charge of $250 will apply to each request for expedited review, in addition to FINRA billing costs. b) The marketing piece must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces over 30 pages require a more in-depth review; therefore, ALPS Distributor cannot guarantee a one business day review for these items. bc) The marketing piece must be submitted via ALPSDistributor’ AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ensure that ALPS Distributor has a full one business day to review and provide Sponsor SC with comments. cd) Sponsor SC must check the box on the AdLit coversheet whereby Sponsor SC requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS Distributor is notified of the expedited request. ALPS . e) Distributor cannot guarantee that a marketing piece will be APPROVED within one business day of being received via AdLit. ALPS Distributor will review and submit comments to Sponsor SC within this timeframe. If Distributor fails to provide SC with comments within one business day, the $250 expedited review charge will not apply.

Advertising and Sales Literature Review. a. ALPS (i) The Distributor shall provide review of broker-dealer related fund advertising and sales literature pieces (“marketing piecesFund Materials”, as defined below) submitted to ALPS Distributor by Sponsor, as well as certain related consultative servicesCCO Capital. b. ALPS’ (ii) Distributor’s services are based on the understanding that Sponsor CCO Capital will utilize current systems and expertise owned by ALPSDistributor, specifically the AdLit Advertising Review System (“AdLit”)) for the review of all marketing pieces, and that ALPS Distributor will base its reviews on: (i) the guidelines contained within ALPS’ Distributor’s Sales and Advertising Guide and ALPS’ Distributor’s Written Supervisory Procedures; (ii) rules and guidance issued by FINRA and the Securities and Exchange Commission (“SEC”) SEC related to communications with the public and/or communications to institutional investors, as those terms are defined in FINRA Rules 2210 and 2211 and in various other FINRA and SEC rules and interpretive material; and (iii) ALPS’ Distributor’s submission guidelines with respect to the use of trademarked and/or copyright materials, to the extent applicable. All material submitted to ALPS Distributor will be provided by ALPS Distributor to Sponsor CCO Capital with comments or approval no later than three business days after receipt in AdLit. c. (iii) Each marketing piece Fund Material submitted to ALPS Distributor for review will be subject to the following process: a) Each piece Fund Material will undergo review at ALPS Distributor by a FINRA-licensed registered principal possessing the required expertise and appropriate license to review the marketing piece Fund Material submitted to ALPSDistributor; b) ALPS’ Distributor’s comments shall consist of (i) recommendations for changes that, in the opinion of the ALPS Distributor reviewer, will be consistent with the guidelines specified by ALPS Distributor in Section 1.b.2(b)(ii) above, or (ii) in the form of an acknowledgement that the submitted material is consistent with such guidelines with no additional changes. In the event of the latter, the item will be approved by the registered principal and filed with the applicable regulatory body if necessary; c) ALPS Distributor will provide system training and ongoing consulting with respect to advertising review guidelines and rules for each marketing piece Fund Material submitted via the process described herein; d) ALPS Distributor will make all required FINRA filings of marketing materials Fund Materials which have been approved by ALPSDistributor. d. (iv) If Sponsor CCO Capital wishes ALPS Distributor to perform an expedited review of marketing pieces Fund Materials within one business day of ALPSDistributor’ receipt of such marketing piecesFund Materials, the expedited review will be performed subject to and in accordance with the following: a) A charge of $250 will apply to each request for expedited review, in addition to FINRA billing costs. b) The marketing piece Fund Materials must be 30 pages or less in actual length in order to be considered for expedited review. Web pages and other marketing pieces Fund Materials over 30 pages require a more in-depth review; therefore, ALPS Distributor cannot guarantee a one business day review for these items. bc) The marketing piece Fund Materials must be submitted via ALPS’ Distributor’s AdLit system by no later than 3:00 P.M. Mountain Time (2:00 P.M. PT/5:00 P.M. ET). This will ensure that ALPS Distributor has a full one business day to review and provide Sponsor CCO Capital with comments. cd) Sponsor CCO Capital must check the box on the AdLit coversheet whereby Sponsor CCO Capital requests and accepts the terms and fee(s) associated with expedited review in order to ensure that ALPS Distributor is notified of the expedited request. ALPS . e) Distributor cannot guarantee that a marketing piece any Fund Material will be APPROVED within one business day of being received via AdLitAdLit from CCO Capital. ALPS Distributor will review and submit comments to Sponsor CCO Capital within this timeframe. If Distributor fails to provide CCO Capital with comments within one business day, the $250 expedited review charge will not apply.