Manager Compliance Questionnare

March 31, 2010

Have there been any changes in your organization? Have you undergone any change in ownership or control? No

Have there been any changes in your investment philosophy? No

Have there been any changes in your staff of investment professionals? Yes, We added Britt Borders

Have you lost a substantial amount of business (amount of percentage of assets under management)? No, $24.7 mil, 1.1%

Have you gained a substantial amount of business (amount of percentage of assets under management)? No

Have there been any new investigations begun by any state or federal government or their agencies, or any charges filed, with regard to any division or unit of your company, and in particular anyone who directly or indirectly performs services for this client? Please provide details (if there is any doubt, please err on the side of providing too much information). No

For managers, with fixed income portfolios that we monitor, are you currently invested in commercial mortgage backed securities (CMBS)? (If yes, please give % of fixed portfolio) No

Are you invested in any unhedged and/or levereged derivatives? No

What percentage of equity is international? The manager must immediately notify the Board and the Consultant when the international exposure reaches ten percent (10%). An explanation will be needed as to why the manager is changing their discipline. (This does not apply to managers that are 100% international equity and to those that have been previously given permission by the board and the consultant) 2.4%

10.

Are you invested in any companies on the SBA's website? (Please review list of scrutinized companies on the following website: http://www.sbafla.com/fsb/ProtectinginvestmentsAct/tabid/402/Default.aspx No

Name of person completing this form (please include company name)?

Michael C. Harhai, Buckhead Capital Management

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