Rule 16a-9

Stock Splits, Stock Dividends, and Pro Rata Rights

The following shall be exempt from section 16 of the Act:

a. The increase or decrease in the number of securities held as a result of a stock split or stock dividend applying equally to all securities of that class, including a stock dividend in which equity securities of a different issuer are distributed.

b. The acquisition of rights, such as shareholder or pre-emptive rights, pursuant to a pro rata grant to all holders of the same class of equity securities registered under section 12 of the Act.

Note: The exercise or sale of a pro rata right shall be reported pursuant to Rule 16a-4 and the exercise shall be eligible for exemption from section 16(b) of the Act pursuant to Rule 16b-6(b).