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Processing Manager

Compliance Department

An Innovative Private Placement Trading Opportunity

We have received a number of requests for additional information regarding the
Programs "administrative hold" feature. Its not surprising. After all, trading against cash
funds or bank instruments placed under administrative hold is a novel procedure.
Something clients (and intermediaries) may not have heard of before - let alone have any
familiarity with. At least, not in the context of private placement opportunities.

Recall that the Genesis Program is an extremely high-ranking Trade Program that
operates at a much higher level than conventional trade programs. There is no Trade
Group! Clients are not required to move their assets (cash funds or bank instruments).
The client's assets are not blocked via SWIFT MT 760. They do not serve as collateral; no
credit lines are arranged against them. All clients are required to do is instruct their bank
to place their account on "administrative hold" for the term of the Program.

This "administrative hold" provision is, in fact, another of the unique and pioneering
features of the Genesis Program. J ust one more exciting attribute of this outstanding
private placement opportunity. And make no mistake about it: We are the only ones on the
planet able to trade against assets placed on administrative hold. And the procedure
well, it is simplicity itself!

Here's what you need to know:

1) After contracts are executed, the client instructs his bank to place his funds or bank
instruments under bank "administrative hold" for a period of one (1) year and one (1)
month, and to confirm the same to the Program Bank via SWIFT. The specimen text of
the Bank Confirmation Letter will be provided to approved applicants.

2) How the administrative hold is, in fact, arranged is up to the client's bank. The client
and his bank officer can work that out together. Frankly, what they do - and how they do it
- makes no difference to us. And is really none of our concern. Typically, though, the
client's bank just puts a "hold" against the clients account on their internal bank screen,
which means the client is unable to withdraw his cash funds or bank instruments from his
account without clearing it first with the bank officer in charge. It is just that simple!

3) Once the placement of the clients cash funds or bank instruments on administrative
hold is confirmed to the Program Bank, the job is done. That's it. We don't contact the
client's bank at all. There is no on-going verification, "pinging" of accounts, phone
calls/faxes to the bank - or anything like that.

4) Importantly, we do not take control of the client's account in any way. The client's
cash funds or bank instruments are not blocked via SWIFT MT 760. They do not
serve as collateral; no credit lines are arranged against them. All that happens is the
client's bank places the client's assets under administrative hold as described above. We
are then able to trade against the bank administrative hold using a technique pioneered by
the Genesis Program.

5) While the clients account is under administrative hold, the client cannot use his cash
funds or bank instruments for any purpose. The client, though, prior to placing his account
on administrative hold, may purchase a Certificate of Deposit or other interest-bearing
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Genesis Program
An Innovative Private Placement Trading Opportunity

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bank instrument. If he does so, the client will receive interest payments, as normal, over
the term of the Program.

6) The client can cancel the administrative hold at any time - and for any reason. Or for no
reason at all. The client simply instructs his bank to release his cash funds or bank
instruments; his bank will then withdraw the administrative hold on his account. Takes five
minutes. The client does not require our permission or approval to do so. In fact, there is
no requirement that the client even notify the Program! The clients actions, of course,
would be in breach of the contract and would operate, therefore, to terminate the clients
participation in the Program.