P-Squared Capital Management
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Trading Policy

August 2013

P-Squared Capital Management maintains separate accounts for each client with TD Ameritrade Institutional.

The order in which P-Squared selects an account to place an order may be random.  Should a security be held in multiple accounts, there is no assurance that the price received for either purchasing or selling that security will be identical to another account (despite the fact that we may use block trades to either buy or sell a position).


P-Squared uses its best judgment, depending upon the circumstances at that moment, to do what it deems to be in the best interest of its clients.


At times, P-Squared may select accounts in alphabetical order or reverse alphabetical order or increasing/decreasing assets under management.  And then again, at times, P-Squared may just randomly select accounts to execute a trade.


There is no assurance that in the course of trading a particular security the price you pay or receive will be identical to the price other clients pay or receive.  From experience, however, we have found that in orderly markets, the difference in prices paid or received from one account to another are fairly similar.  When a market is not orderly, significant differences in prices may be realized.



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