IMPORTANT DISCLOSURES

Tudor, Pickering, Holt & Co. uses a Buy, Accumulate, Hold, Trim and Sell rating system.

Opinion Key:
Buy - The stock should be purchased aggressively at current prices. The stock has among the best combination of risk/reward and positive company specific catalysts within the sector. Stock is expected to trade higher on an absolute basis and be a top performer relative to peer stocks over the next 12 months.

Accumulate - The stock should be purchased consistently at current prices. The stock has above average risk/reward and is expected to outperform peer stocks over the next 12 months.

Hold - Do nothing with the stock at current prices. The stock has average risk/reward and is expected to perform in line with peer stocks over the next 12 months.

Trim - The stock should be sold consistently at current prices. The stock has below average risk/reward and is expected to under perform peer stocks over the next 12 months.

Sell - The stock should be sold aggressively at current prices. The stock's risk/reward is skewed to the downside with possible negative company specific catalysts or excessive valuation. The stock is expected to trade lower on an absolute basis and be among the worst performers relative to peer stocks over the next 12 months.

Investment Rating Distribution: (as of December 31, 2009)

Coverage Universe -

Stock Rating Category	Count	% of Total
Overweight / Buy	61	67%
Equal-weight / Hold	29	32%
Underweight / Sell	1	1%

Tudor, Pickering, Holt & Co. has received in the past 12 months compensation for investment banking or other services from Anadarko Petroleum, Chesapeake Energy, Constellation Energy, El Paso Pipeline Partners, Gastar Exploration, GMX Resources, Goodrich Petroleum Corp., Legacy Reserves, Magellan Midstream Partners, Mariner Energy, Nabors Industries, ONEOK, Petrohawk Energy, Quest Resources, Regency Energy Partners, Rosetta Resources, SandRidge Energy, Stone Energy, and XTO Energy. We intend to seek compensation for investment banking services from the companies we follow in the next 3 months. 

Investment Rating Distribution of Investment Banking Clients: (as of December 31, 2009)

Coverage Universe -

Stock Rating Category	Count	Percent
Overweight / Buy	11	85%
Equal-weight / Hold	2	15%
Underweight / Sell	0	0%

Price Target Methodology:
Price targets are developed using the stock's forward price-to-earnings ratio as a primary valuation metric.  Target prices are typically 20-25X forward price-to-earnings for oil service companies, with validation of this range is driven by examination of EBITDA multiples and price-to book value metrics.  For offshore drilling companies, price targets are developed using 10-15X multiples of upside earnings.  These are calculated using our assumptions of normalized day rates and utilization.  Validation of our target is done by examining net asset values, and private market transactions.  There is a risk that the stock will never reach the price target. These risks include market conditions and unforeseen events that may affect the company's business.

For pipelines, price targets are developed using a sum of the parts methodology, valuing the individual business units on pertinent industry metrics and then netting out debt.  For pipelines, we typically used 9x forward year EBITDA.  If the company plans to place the assets into an MLP, we will value a portion of their pipeline assets at a higher multiple, up to 12x forward year EBITDA.  LDC (local gas distribution utility) assets we value at 8-9x forward year EBITDA, depending on the quality of the regulatory jurisdiction and growth.  For E&P businesses, we value proved reserves by assessing the net present value of current production.  For probable and possible reserves, we attempt basin-by basins analysis of the reserves, with the key variable being the timing of drilling.  Midstream assets we value at 8x forward year EBITDA.  And for trading, we value the asset at 1x the value of the trading book, assuming that information is available.  There is a risk that the stock will never reach the price target. These risks include market conditions, commodity prices, regulatory rulings and rate case outcomes, tax law changes, project execution, weather, interest rates and unforeseen events that may affect the company's business.

BUSINESS CONTINUITY  PLAN
Executive Summary

As required by securities industry regulations, Tudor, Pickering, Holt & Co. wants to make you aware that we have developed a Business Continuity Plan on how we will respond to events that disrupt our business.  Since the timing and impact of disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. 

Our Business Continuity Plan - Significant business disruptions can vary from disrupting only our firm to the region in which we are located.  Our Plan addresses various disruptions and is intended to mitigate reasonable risk so as to permit the continuation of key business operations. Our Business Continuity Plan addresses data back up and recovery, mission critical systems, safeguarding our employees and property, financial and operational assessment, alternative communications with customers, employees and regulators, alternate physical location of employees, critical supplier and bank, and counterparty impact, regulatory reporting and assuring our customers prompt access to their funds and securities and allowing our customers to transact business. 

Tudor, Pickering, Holt & Co maintains redundant offsite archival storage facilities in a geographically separate area.  Our clearing firm, the Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated, also backs up certain of our records.  We have designated an alternate site to conduct key business operations until we are able to return to our offices.  The firm's goal is to recover its critical operations within minutes or hours after the disruption.  We will assure our customers prompt access to their funds and securities. 

Contacting Us - In the event of a business disruption Tudor, Pickering, Holt & Co.  will provide information to its employees and clients via call forwarding, e-mail and other telecommunication services.  Our address is:

Heritage Plaza
1111 Bagby, Suite 5100
Houston, TX 77002
713.333.2960

If you are unable to contact us through those means you may contact our clearing firm, the Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated, for trade related information.  Their contact information is as follows:

Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated
101 Hudson Street
Jersey City, NJ  07302
201-557-0700

The plan is subject to modification, an updated summary will be promptly posted on our website, www.tudorpickering.com.   Customers may alternatively obtain updated summaries by requesting a written copy by mail.

Trade Execution Data: 
SEC-Required Report on Routing of Customer Orders
For Quarter Ending December 2009 

Tudor, Pickering, Holt & Co. has prepared this report pursuant to a U.S. Securities and Exchange Commission rule requiring all brokerage firms to make publicly available quarterly reports on their order routing practices. The report provides information on the routing of "non-directed orders" - any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, Tudor, Pickering, Holt & Co. has selected the execution venue on behalf of its customers.

The report is divided into four sections: one for securities listed on the New York Stock exchange, one for securities listed on The Nasdaq Stock Market, one for securities listed on the American Stock Exchange or regional exchanges, and one for exchange-listed options. For each section, this report identifies the venues most often selected by Tudor, Pickering, Holt & Co., sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of Tudor, Pickering, Holt & Co.'s relationship with the venues.

713.333.2960
info@tudorpickering.com