Given the turmoil and uncertainty we face today, we at Spicer Jeffries LLP would like to provide to you, our valued clients and our client’s investors, some information regarding our firm.

Over the past twenty-five years, our firm has provided audit and tax services to many clients which encompass the entire spectrum of the securities and commodities industry.  We have worked with both full clearing and fully disclosed broker-dealers, investment advisors and all types of investment funds (i.e. hedge, commodity and private equity), both domestic and offshore.  Our firm formerly was the Denver office of Spicer & Oppenheim (formerly Oppenheim, Appel, Dixon & Co.), a firm based in New York and London whose national expertise was in securities and commodities.  In fact, up until their dissolution in 1990, they had more securities clients throughout the United States than any other accounting firm.  We believe that our past experiences and expertise rivals that of any other firm working in the industry.

As a recognized expert in the industry, we were selected, along with four of the largest accounting firms in the United States, to implement FINRA's (formerly the NASD) Annual Audit Automation Pilot Program for securities broker-dealers.  We have worked with and represented our clients before the SEC and FINRA.

Spicer Jeffries LLP is currently registered in multiple states, including Colorado, California, Florida, Massachusetts, New York and Washington, among others.  We are a member of the Center for Audit Quality (“CAQ”) of the American Institute of Certified Public Accountants (“AICPA”).  We are also registered with the Public Company Accounting Oversight Board (“PCAOB”), an organization created by the Sarbanes-Oxley Act of 2002 to regulate auditors of public entities.  We registered with the PCAOB in 2003.  As a PCAOB firm, we are allowed to conduct audits of companies registered with the SEC.

Member firms of the CAQ are subject to peer review every three years in accordance with the AICPA’s Center for Public Company Audit Firms Peer Review Program.  Our peer reviews are conducted by an independent accounting firm that is familiar with accounting principles generally accepted in the United States of America, auditing standards generally accepted in the United States of America and the industries in which we practice.  The peer review firm performs a detailed analysis of our quality control program, interviews employees at all staff levels, selects a sample of audit files and reviews such audit files to ensure that the audits were conducted in accordance with the applicable standards.

Since the inception of our firm in 1992, we have received favorable peer review reports in each peer review period.  Our independent peer review firm last conducted and issued our peer review report on June 8, 2006.  Each CAQ member firm’s peer review report is public information and can be viewed on the AICPA’s website (www.aicpa.org).  Our latest peer review report is accessible as follows:

1.       Go to www.aicpa.org
2.       Select peer review public file under the Consumer Information drop down menu located on the left of the web page
3.       Click on Continue onto public file
4.       Type “Spicer” in the Firm Name field and click on submit
5.       Click on Spicer Jeffries LLP
6.       Click on Review Documents to see our June 8, 2006 peer review report

As an approved PCAOB firm, we are also subject to a peer review by the staff of the PCAOB once every three years.  Since our acceptance by the PCAOB, we have been subject to two PCAOB inspections.  We received inspection reports dated October 27, 2005 and November 13, 2008.  Both inspection reports stated that the inspection did not identify any audit performance issues that, in the inspection team’s view, resulted in our firm failing to obtain sufficient competent evidential matter to support its opinion on the issuer’s financial statements.  Both inspection reports are available through the PCAOB’s website (www.pcaob.org) as follows:

1.       Go to www.pcaob.com
2.       Click on Inspection Reports of the Inspections drop down menu located at the top of the web page
3.       Click on Spicer Jeffries LLP (10/27/05) and/or Spicer Jeffries LLP (11/13/08)

Spicer Jeffries (Cayman), a subsidiary of Spicer Jeffries LLP, was approved on November 13, 2008 by the Cayman Islands Monetary Authority (“CIMA”) to perform audits of mutual funds domiciled in the Cayman Islands.  A copy of our acceptance as an approved auditor is available upon request.