Private Placement Procedures

If you want to invest in a private placement (e.g., private equity or debt offering), you should follow these three basic steps:

A) Make sure the private placement has been filed with PENSCO Trust

1. Print out PENSCO Trust’s Private Investment Guidelines for Investment Sponsors

2. Provide this document to the entity (e.g., company or investment sponsor) into which you expect to invest for its completion;

3. Instruct the investment sponsor to forward the information requested for the type of entity that they are (e.g., C-corp (corporate stock), Limited Liability Company, Limited Partnership, etc.) to PENSCO Trust;

4. Be sure to instruct the sponsor to complete page 4 of the Private Investment Guidelines. We will not accept a private placement unless the investment sponsor completes, signs and submits page 4 along with the other requested information.

Once we receive the sponsor’s investment materials as outlined in the Private Investment Guidelines, we will review them for acceptance. We log all items we receive, and we can inform of their disposition at any time. Please allow us 48 hours following receipt before contacting us, to provide us the time to review them.

Once the asset is accepted into our system, you will now be able to instruct us to fund your investment. This assumes you already have a funded PENSCO Trust IRA. If not, follow the next step..

B) Make sure you have available cash in an IRA at PENSCO Trust

You will need to open an account and have your funds received and cleared by PENSCO Trust before you will be able to fund. It generally takes 2-3 weeks to receive funds from another institution, once they have received our transfer form. We will send out your transfer form the day we receive it from you.

C) Authorize your investment transaction. Fax or mail two things to us:

1. PENSCO Trust’s Investment Authorization for Non-Publicly Traded Investments form
   
   a. Use this form to specify how, how much, and where to fund. Form must be signed by IRA Owner, copy acceptable.
   
   b. The investor agreement from the entity, drawn up with your IRA’s name as the investor (PENSCO Trust Company, Custodian FBO ‘Your Name’ IRA, Acct. #). For example, when in investing an IRA into an LLC, this document might be the LLC’s ‘Subscription Agreement’. The investment amount and name of entity must match those reiterated on the above form.

PENSCO Trust takes over.

Our system automatically tracks investment submissions, completed investment authorization forms, and collected funds. Thus, once the investment is accepted, your funds received, and you’ve given us the authorization to invest, we guarantee 48-hour funding or there is no charge for the transaction.