<table><tr><th>From:</th><th>Ada Clapp</th></tr><tr><td>Sent:</td><td>Monday, September 15, 2014 5:25 PM</td></tr><tr><td>To:</td><td>Jeffrey E.</td></tr><tr><td>Subject:</td><td>Roth IRA question</td></tr></table>

I have not yet heard back from my former colleague a= US Trust. I will also ask him about a Trusteed Roth IRA (with=the thought that the borrower's Roth IRA be converted to a Trusteed =oth IRA).

I have not done one of these but my understanding is=that it works like a trust after the IRA owner dies or becomes incompetent= With the Trusteed IRA, I believe it is possible for the IRA owner t= name you as a beneficiary for the outstanding amount of the loan after his death. This would at least give you &nb=p;some protection if he dies (or becomes incapacitated) before he reaches =ge 59.1/2 and has met the 5-year requirement. Perhaps the Trust Agre=ment could even be drafted to mandate distributions to you of the amount loaned once the IRA owner has reached age 59-1/2 and =et the 5-year requirement. I know Merrill Lynch does these so my for=er colleague may know.

Ada Clapp

Elysium Management LLC

445 Park Avenue

Suite 1401

New York, New York 10022

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