October 14, 2002

Statement of adoption of Investment Protection Principles

First Analysis Securities Corporation has adopted the Investment Protection Principles (derived from the May 2002 Merrill-Spitzer agreement) as communicated Sept. 11, 2002, by Alliance Capital Management Corp., on behalf of the State Treasurer of North Carolina and the Comptroller of New York State.

First Analysis Securities Corp. (FASC) is a registered broker/dealer with FINRA and member SIPC.