Dana Investment Advisors, Inc. (Dana) is an independent investment management firm established in 1980. Dana manages a variety of equity, fixed income and balanced portfolios for primarily U.S. institutional clients. Dana maintains a complete list and description of composites, which is available upon request.

The benchmark for the Dana Small Cap Equity composite is the Russell 2000 Index. (Market Capitalization Weighted). The Russell 2000® Index is a egistered trademark of the Frank Russell Company. Dana is not affiliated with the Frank Russell Company or the Russell indexes. Reported benchmarks are not intended as direct comparisons to the performance of the portfolio. Instead, they are intended to represent the performance of certain sectors of the overall securities market. The indices reflect the reinvestment of dividends and income and do not reflect deductions for fees, expenses or taxes. The indices are unmanaged and are not available for direct investment.

The composite was created July 31, 1999. Performance is calculated in US Dollars utilizing a time-weighted total rate of return which includes the reinvestment of dividends and income. Total return for the composite is represented by the asset-weighted returns of the portfolios within the composite. Trade-Date valuation is used.

The Dana Small Cap Equity composite does not have a minimum size criterion for composite membership. All fee-paying, discretionary accounts with similar investment objectives are included. The composite includes the equity segment of balanced accounts. Cash is allocated to these segments based on the average cash position of the "equity only" portfolios in the composite. Leverage is not used in this composite as a means to generate higher returns. The composite does not contain any non-fee paying portfolios.

The dispersion of annual returns is measured by the standard deviation of equal-weighted portfolio returns represented within the composite for the full year. The standard deviation presented is based upon annualized quarterly standard deviation of returns. The standard deviation of the annual returns presented for the time period 2000 to 2009 is 21.90% for the composite and 22.12% for the Russell 2000 Index.

Performance results are calculated and presented before investment management and custodial fees, but after all applicable trading costs. The composite contains both traditional commission paying and bundled-fee portfolios. Transaction costs are allocated to bundled-fee portfolios at the current prevailing per share commission rate charged by our preferred list of non-directed institutional brokers. Bundled fee portfolios comprise 14.4% of composite assets as of 12/31/09. Dana investment management fees may vary based upon the differences in size, composition and servicing needs of client accounts. Investment management fees would reduce the returns presented, for example: a $1,000,000 portfolio with an advisory fee of 0.75% per annum earning a 10% annual return would have paid a total compounded advisory fee of $50,368 over a five year period. The resulting average annual return for the period would be 9.17%. Past performance is not indicative of future results. A complete description of Dana's investment advisory fee schedule is contained in the Firm's Form ADV Part II, a copy of which is available upon request.