Summerlin Asset Management Legal Disclaimer

No material on this website is to be construed as a solicitation or offer, or recommendation, to buy or sell any interest in any note, trust deed, mortgage, or other security, or to engage in any other transaction, and the content herein does not constitute, and should not be considered to constitute, an offer of securities. No statement herein made constitutes an offer to sell or a solicitation of an offer to buy a note or other security. Individuals who wish to learn more about Summerlin Asset Management and opportunities for investing in Summerlin Asset Management should contact a representative through this website.

All investments have risk, and investing in Summerlin Asset Management may have particular risks that should be understood by potential investors. Investments with Summerlin Asset Management may not be available to all investors in all states. Any investment opportunities available with Summerlin Asset Management will only be offered to investors who qualify.

Prospective investors are not to construe the contents of investinsam.com or any other documents delivered to the investor as legal, business, accounting or tax advice. Each prospective investor should consult his or her own attorney, business or tax advisor as to legal, business, tax and related matters concerning private mortgage investment. Investors are expected to conduct and rely on their own due diligence, including the merits and risks involved in Summerlin Asset Management’s valuation, in making their investment decision. Summerlin Asset Management cannot predict with certainty and does not guarantee the size of any return, and, while our business is based on avoiding risk, investors may experience declines in the value of their investment and/or its underlying collateral.

All of the statements made herein with respect to projected investment results are based on information projected to the best of management’s knowledge, or sources believed by management to be reliable. No representations are made as to the accuracy or attainment of such results, estimates, or implications as to investment performance, and we do not guarantee the accuracy of such statements. Past performance is not necessarily a guide to the future performance of an investment. Prospective investors should be aware that any information contained herein is subject to change without notice.

Summerlin asset Management is a private company and is not subject to the reporting requirements of the Securities Exchange Act of 1934, as amended and, therefore, does not file reports, proxy statements or other financial information with the Securities and Exchange Commission.

State Specific legal disclaimers:

Virginia

THE SECURITIES REPRESENTED BY THIS CERTIFICATE (OR OTHER DOCUMENT) HAVE BEEN ISSUED PURSUANT TO A CLAIM OF EXEMPTION FROM THE REGISTRATION OR QUALIFICATION PROVISIONS OF FEDERAL AND STATE SECURITIES LAWS AND SHALL NOT BE SOLD OR TRANSFERRED WITHOUT COMPLIANCE WITH THE REGISTRATION OR QUALIFICATION PROVISIONS OF APPLICABLE FEDERAL AND STATE SECURITIES LAWS OR APPLICABLE EXEMPTIONS THEREFROM;

Texas:

(A) the dealer, investment adviser, dealer agent, or investment adviser representative in question may only transact business in this state if first registered, excluded, or exempted from Texas dealer, investment adviser, dealer agent, or investment adviser representative registration requirements, as may be; and

(B) follow-up, individualized responses to persons in Texas by such dealer, investment adviser, dealer agent, or investment adviser representative that involve either the effecting or attempting to effect transactions in securities, or the rendering of personalized investment advice for compensation, as may be, will not be made absent compliance with Texas dealer, investment adviser, dealer agent, or investment adviser representative registration requirements, or an applicable exemption or exclusion;

Tennessee:

IN MAKING AN INVESTMENT DECISION INVESTORS MUST RELY ON THEIR OWN EXAMINATION OF THE ISSUER AND THE TERMS OF THE OFFERING, INCLUDING THE MERITS AND RISKS INVOLVED.

THESE SECURITIES HAVE NOT BEEN RECOMMENDED BY ANY FEDERAL OR STATE SECURITIES COMMISSION OR REGULATORY AUTHORITY. FURTHERMORE, THE FOREGOING AUTHORITIES HAVE NOT CONFIRMED THE ACCURACY OR DETERMINED THE ADEQUACY OF THIS DOCUMENT.

ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL OFFENSE. THESE SECURITIES ARE SUBJECT TO RESTRICTIONS ON TRANSFERABILITY AND RESALE AND MAY NOT BE TRANSFERRED OR RESOLD. EXCEPT AS PERMITTED UNDER THE SECURITIES ACT OF 1933, AS AMENDED AND THE APPLICABLE STATE SECURITIES LAWS, PURSUANT TO REGISTRATION OR EXEMPTION THEREFROM. INVESTORS SHOULD BE AWARE THAT THEY MAY BE REQUIRED TO BEAR THE FINANCIAL RISK OF THIS INVESTMENT FOR AN INDEFINITE PERIOD OF TIME.

North Dakota:

(a) NO MONEY OR OTHER CONSIDERATION IS BEING SOLICITED AND NONE WILL BE ACCEPTED;

(b) NO SALES OF THE SECURITIES WILL BE MADE OR COMMITMENT TO PURCHASE ACCEPTED UNTIL DELIVERY OF A PROSPECTUS OR SIMILAR DISCLOSURE DOCUMENT THAT INCLUDES COMPLETE INFORMATION ABOUT THE ISSUER AND THE OFFERING;

Page No. 13c) AN INDICATION OF INTEREST MADE BY A PROSPECTIVE INVESTOR INVOLVES NO OBLIGATION OR COMMITMENT OF ANY KIND; and

(d) THIS OFFER IS BEING MADE PURSUANT TO AN EXEMPTION FROM REGISTRATION UNDER THE FEDERAL AND STATE SECURITIES LAWS. NO SALE MAY BE MADE UNTIL THE OFFERING STATEMENT IS QUALIFIED BY THE SECURITIES AND EXCHANGE COMMISSION AND IS REGISTERED OR APPROVED IN THIS STATE.

(2) Any script for broadcast must contain at least the identity of the chief executive of the issuer, a brief description of its business and products, its address and telephone number, and the following legends:

(a) THIS IS FOR AN INDICATION OF INTEREST ONLY AND INVOLVES NO OBLIGATION OR COMMITMENT OF ANY KIND UPON A PROSPECTIVE INVESTOR;

(b) NO MONEY OR OTHER CONSIDERATION IS BEING SOLICITED;

and

(c) THIS OFFER IS MADE PURSUANT TO AN EXEMPTION FROM REGISTRATION.

Arkansas:

(e) EXCEPTIONS. The following forms and types of advertising are permitted without the necessity for filing or prior authorization by the Commissioner, unless specifically prohibited: (1) So-called “tombstone” advertising, containing no more than the following information: (A) Name and address of issuer; (B) Identity of title of security;(C) Per unit offering price, number of shares and amount of offering; (D) Brief, general description of business; (E) Name and address of underwriter, or address where offering circular or prospectus can be obtained; and (F) Date of issuance.

Arizona:

“THIS IS NEITHER AN OFFER TO SELL NOR A SOLICITATION OF AN OFFER TO BUY THE SECURITIES DESCRIBED HEREIN. THE OFFERING IS MADE ONLY BY THE PROSPECTUS.”

Alabama:

“THE UNITS OFFERED HEREBY HAVE NOT BEEN REGISTERED UNDER THE SECURITIES ACT OF 1933, AS AMENDED (THE “ACT”), OR THE SECURITIES LAWS OF CERTAIN STATES AND ARE BEING OFFERED AND SOLD IN RELIANCE ON EXEMPTIONS FROM THE REGISTRATION REQUIREMENTS OF THE ACT AND SUCH LAWS. THE UNITS HAVE NOT BEEN APPROVED OR DISAPPROVED BY THE SECURITIES AND EXCHANGE COMMISSION, ANY STATE SECURITIES COMMISSION OR OTHER REGULATORY AUTHORITY, NOR HAVE ANY OF THE FOREGOING AUTHORITIES PASSED UPON OR ENDORSED THE MERITS OF THIS OFFERING OR THE ACCURACY OR ADEQUACY OF THIS MEMORANDUM. ANY REPRESENTATION TO THE CONTRARY IS UNLAWFUL.