Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of MSCS Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.

OPTECH SYSTEMS INC.

SEC Rule 22c-2SEC Rule 22c-2

Matrix’ Support of Matrix’ Support of

and and

Planned Compliance with the RulePlanned Compliance with the Rule

OPTECH SYSTEMS INC.

Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.

What Led to Rule 22c-2?What Led to Rule 22c-2?

In March 2005 the SEC adopted Rule 22c-2 in an In March 2005 the SEC adopted Rule 22c-2 in an effort to deal with market timing concerns.effort to deal with market timing concerns.

The Rule specifically addresses the imposition and The Rule specifically addresses the imposition and treatment of redemption fees.treatment of redemption fees.

It requires that each mutual fund’s board must eitherIt requires that each mutual fund’s board must either Approve a redemption fee, orApprove a redemption fee, or Determine that a redemption fee is either not necessary or Determine that a redemption fee is either not necessary or

not appropriate.not appropriate.

OPTECH SYSTEMS INC.

Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.

Rule 22c-2: RequirementsRule 22c-2: Requirements

Regardless of whether a fund imposes a redemption fee, the Regardless of whether a fund imposes a redemption fee, the fund will be required to enter into a written agreement with fund will be required to enter into a written agreement with each “Financial Intermediary”.each “Financial Intermediary”.

The agreement must include language whereby the Financial The agreement must include language whereby the Financial Intermediary agrees to:Intermediary agrees to: Provide the Tax Identification Number of the shareholder upon request Provide the Tax Identification Number of the shareholder upon request

from the fund along with the amounts and dates of the shareholder’s from the fund along with the amounts and dates of the shareholder’s transaction(s).transaction(s).

Execute any instructions from the fund to restrict or further prohibit the Execute any instructions from the fund to restrict or further prohibit the shareholder’s activity that violates the polices of the fund.shareholder’s activity that violates the polices of the fund.

The Rule is scheduled to go into effect October 16, 2006.The Rule is scheduled to go into effect October 16, 2006.

OPTECH SYSTEMS INC.

Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.

Rule 22c-2: Points of ConcernRule 22c-2: Points of Concern

Fund AgreementsFund Agreements The Rule did not address the “Chain of Intermediary The Rule did not address the “Chain of Intermediary

Situations” whereby Matrix was not identified as a type of Situations” whereby Matrix was not identified as a type of intermediary.intermediary.

Without a change to the definition of a Financial Without a change to the definition of a Financial Intermediary, Matrix’ customers would be forced to Intermediary, Matrix’ customers would be forced to execute new shareholder information agreements with each execute new shareholder information agreements with each mutual fund they do business with. mutual fund they do business with.

OPTECH SYSTEMS INC.

Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.

Rule 22c-2: Matrix RespondsRule 22c-2: Matrix Responds

Matrix has been in communication with the ICI and Matrix has been in communication with the ICI and took the lead in a campaign to change the definition took the lead in a campaign to change the definition of a Financial Intermediary.of a Financial Intermediary.

It is expected that the SEC will give mutual funds the It is expected that the SEC will give mutual funds the discretion to allow Matrix to sign these agreements in discretion to allow Matrix to sign these agreements in its role as trading agent for the Financial Intermediary its role as trading agent for the Financial Intermediary as that term is defined in the rule.as that term is defined in the rule.

OPTECH SYSTEMS INC.

Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.

Rule 22c-2: Data Reporting Rule 22c-2: Data Reporting RequirementsRequirements

All requests for information by the mutual funds will be All requests for information by the mutual funds will be received by Matrix for accounts where we are listed as trading received by Matrix for accounts where we are listed as trading agent.agent.

Matrix will notify each client when a request for underlying Matrix will notify each client when a request for underlying account information is received.account information is received.

The data for the funds is housed in Matrix’ clients’ trust The data for the funds is housed in Matrix’ clients’ trust accounting and/or recordkeeping systems.accounting and/or recordkeeping systems.

Clients’ system vendors should begin making the necessary Clients’ system vendors should begin making the necessary enhancements to allow this data to be transmitted to Matrix.enhancements to allow this data to be transmitted to Matrix.

Matrix will provide electronic delivery of this data to the funds Matrix will provide electronic delivery of this data to the funds via the NSCC.via the NSCC.

OPTECH SYSTEMS INC.

Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of Matrix Settlement & Clearance Services, LLC is a wholly owned subsidiary of MG Colorado Holdings, Inc. Affiliates include: MSCS Financial Services, LLC (a subsidiary of MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.MSCS and a member of the NASD & SIPC); MG Trust Company, LLC; MG Advisory Services, LLC; and Optech Systems, Inc.

Next StepsNext Steps

Occasional updates will be provided through Occasional updates will be provided through future web cast presentations on our website.future web cast presentations on our website.

Our annual client conference (August 13-16) Our annual client conference (August 13-16) will feature a panel discussion of Rule 22c-2 will feature a panel discussion of Rule 22c-2 including industry experts.including industry experts.