1. (a) deliver to a client or prospective client either a copy of the investment adviser statement Form ADV, or a brochure containing all of the information set forth therein, before or at the time of entering into an investment advisory contract with that client; and

2. (b) deliver to each client, annually within 120 days after the end of the fiscal year of such adviser, and without charge, if there are material changes in such statement or brochure since any annual updating amendment:

   1. (1) a current statement or brochure; or
   2. (2) the summary of material changes to any statement or brochure as required by item 2 of Form ADV, part 2A that offers to provide your current brochure without charge, accompanied by the web site address (if available) and an e-mail address (if available) and telephone number by which a client may obtain the current statement or brochure from you, and the web site address for obtaining information about you through the investment adviser public disclosure (IAPD) system.

Each investment adviser registered in the State of New York must: