Massachusetts Securities Division

Acting as an investment adviser representative of 1620 Investment Advisors, Inc. without being so registered since January 1,2005.

Consent

Back registration fees and administrative assessments

Mr. Johnston was initially registered properly with the Commonwealth of Massachusetts. Due to an administrative error at the State Securities Division, Mr. Johnston's registration did not carryforward when the state began to utilize the electronic systems through FINRA. While this error originated within the Massachusetts Securities Division, Mr. Johnston found this error through his own internal review and self-reported this issue to the Massachusetts Securities Division. The 1620 employees responsible for monitoring the registration process for the Advisor did not catch this clerical error during the annual fee payment process for the firm and its advisory persons. The company regrets that this clerical error persisted for the period noted herein.