Summit Trail Advisors, LLC

A. Services For certain legacy relationships, the Advisor provides discretionary and/or non-discretionary investment advisory services on a wrap fee basis (See discussion below). Under a wrap fee, basis the Client will pay a single fee for bundled services (i.e., investment advisory, brokerage, custody). The services included in a wrap fee agreement will depend upon each Client’s particular need. The Advisor’s investment management services on a wrap fee basis are in accordance with the Summit Trail Wrap Program (the “Program”). Under the Program, the Advisor is able to offer participants discretionary and/or non-discretionary investment management services, for a single specified annual Program fee, inclusive of trade execution, custody, reporting, account maintenance, investment management fees, andfees charged by independent managers. However, Clients may be responsible for, but not limited to, trustee fees, mutual fund expenses, ETF expenses, mark-ups, mark-downs, transfer taxes, odd lot differentials, exchange fees, interest charges, American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with regard to Client accounts. These fees and expenses are described in each fund’s prospectus. Summit Trail can provide or direct you to a copy of the prospectus for any fund that we recommend to you. Such fees are in addition to any fees paid by the Client to the Advisor and are between the Client and the account custodian. The current annual Program fee ranges up to 2.00%, as follows: Assets Under Management Less than $5,000,000 $5,000,000 to $10,000,000 $10,000,000 to $25,000,000 $25,000,000 to $50,000,000 $50,000,000 to $100,000,000 More than $100,000,000

Annualized Fee 2.00% 1.75% 1.50% 1.30% 1.10% 1.00%

Under the Program, if engaged on a discretionary basis, the Advisor shall have written authority to determine the type and amount of securities that are bought or sold. Clients who engage the Advisor on a discretionary basis may, at any time, impose restrictions, in writing, on the Advisor’s discretionary authority (i.e., limit the types/amounts of particular securities purchased for their account(s), exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe the Advisor’s use of margin, etc.). Pershing, LLC (“Pershing”) and/or Fidelity Institutional Wealth Services, (“Fidelity”) shall serve as the custodian for Program accounts. Use of Independent Managers: For Client account[s] implemented through an Independent Manager (“Independent Managers”), the Client’s overall fees may include Summit Trail’s investment advisory fee (as noted above) plus advisory fees and/or platform fees charged by the Independent Manager[s], as applicable. The Independent Manager may assume responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s]. In such instances, Summit Trail will not charge its fee separately on those assets. Turnkey asset management programs (“TAMP”) related charges are not included in the investment management fee you pay to Summit Trail. You will be charged, separate from and in addition to your investment management fee, any applicable TAMP fees as well as applicable Independent Manager fees.

The Advisor is affiliated with Dynasty Financial Partners, LLC (“Dynasty”), Dynasty is also a TAMP provider (See Item 6 below). The Advisor does not receive any portion of the fees paid directly to Dynasty or the service providers made available through Dynasty’s TAMP, including the Independent Managers. TAMP and Independent Manager fees are determined by the particular TAMP and Independent Manager[s] with which Client assets are invested, and are calculated based upon a percentage of assets under management, as applicable. The program fee generally ranges up to 0.45% annually. Clients should note the total fees reflected on custodial statements represent the aggregate of Summit Trail’s investment management fee, TAMP fee and Independent Manager fee, accordingly. Clients are urged to review such statements to determine the total amount of fees associated with assets placed with Independent Managers. Client should also review the investment management agreement with Summit Trail to determine the investment management fee paid to the Advisor. Fee Calculation: The fee charged is calculated as described above and is not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of a Client. Client’s may make additions to and withdrawals from their account(s) at any time. However, reconciliations are performed on a quarterly basis to capture the difference in the market value of the assets on the last day of the previous quarter and the average daily balance of the assets for the quarter. An adjustment will be made in the form of a credit or debit to reflect the difference. For the initial period of an engagement, the fee is calculated on a pro rata basis through the end of the quarter. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the unearned portion is refunded to the Client, as appropriate. The Advisor may also provide investment advisory services with respect to non-custodial partnership/private fund investments, which are not held at the Primary Custodian. In such instances, the Client shall be required to complete the applicable private placement and/or account opening documents to establish these investments. The Advisor will debit its fee for providing investment advisory services with respect to these relationships directly from a brokerage account designated by the Client held at the Primary Custodian. For certain non-custodial partnership/private fund investments, the Advisor may not receive quarter-end investment valuations prior to its fee billing calculation. In such instances, the Advisor will use the most recent month-end or quarter-end valuation available for the calculation of investment advisory fees. The Advisor will recalculate its fee upon receipt of final valuations. Adjustments are reflected in the fee calculations for the next quarterly period. Fee Payment: Clients will be charged in advance, at the beginning of each calendar quarter based upon the market value of the assets on the last business day of the previous quarter. Clients may elect to have the Advisor’s advisory fees deducted from their custodial account(s). Investment Performance: As a condition to participating in the Program, the participant must accept that past performance may not be indicative of future results, and understand that the future performance of any specific investment or investment strategy (including the investments and/or investment strategies purchased and/or undertaken by the Advisor) may not: (1) achieve their intended objective; (2) be profitable; or, (3) equal historical performance level(s) or any other performance level(s). The Advisor’s Chief Compliance Officer (“CCO”), Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding this Wrap Fee Program Brochure.

B. Program Costs Participation in the Program may cost more or less than purchasing such services separately. Also, the Program fee charged by Advisor for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. Depending upon the percentage wrap-fee charged by the Advisor, the amount of portfolio activity in the Client's account(s), and the value of custodial and other services provided, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately and/or if the Advisor were to negotiate transaction fees and seek best price and execution of transactions for the Client's account(s). Conflict of Interest: Because Program transaction fees and/or commissions are being paid by the Advisor to the account custodian/broker-dealer, the Advisor has an economic incentive to minimize the number of trades in the Client's account(s). The Advisor’s Chief Compliance Officer, Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding the corresponding conflict of interest a wrap fee arrangement may create. C. Fees The Program’s wrap fee does not include certain charges and administrative fees, including, but not limited to, trustee fees, mutual fund expenses, ETF expenses, markups, mark-downs, transfer taxes, odd lot differentials, exchange fees, interest charges American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with regard to Client accounts. Such fees and expenses are in addition to the Program’s wrap fee. Tradeaway/Prime Broker Fees. Relative to its discretionary investment management services, when beneficial to the Client, individual fixed income transactions may be effected through broker-dealers other than the account custodian, in which event, the Client generally will incur both the fee (commission, markup/mark-down) charged by the executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account custodian (Pershing and/or Fidelity). Please Note: Clients who engage the Advisor on a wrap fee basis may incur tradeaway and/or prime broker fees. D. Compensation Advisor’s related persons who recommend the Program to Clients do not receive additional compensation as a result of a Client’s participation in the wrap fee program.

The Advisor’s Clients shall generally include individuals, high net worth individuals, business entities, trusts, estates, charitable organizations, and pension and profit sharing plans. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. The Advisor, in its sole discretion, may charge a lesser investment advisory fee, or a flat fee, based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition,

competition, negotiations with Client, etc.). The Advisor generally does not impose a minimum relationship size for establishing a relationship. However, certain strategies of STA may require a minimum asset amount in order to achieve optimal returns based on the needs of the Client, which may be waived at the sole discretion of the Advisor. As result, similarly situated Clients could pay differentfees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees.

The Client shall have, without restriction, reasonable access to the Program’s portfolio manager.

The Advisor shall be the Program’s portfolio manager. The Advisor shall provide investment advisory services specific to needs of each Client. Prior to providing investment advisory services, an investment adviser representative will discuss with each Client, their particular investment objective(s). The Advisor shall allocate each Client’s investment assets consistent with their designated investment objective(s). Clients may, at any time, impose restrictions, in writing, on the Advisor’s services. As indicated above, each Client is advised that it remains their responsibility to promptly notify the Advisor if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Advisor’s previous recommendations and/or services. To the extent the Program utilizes independent manager(s), the Advisor shall provide the independent manager(s) with each Client’s particular investment objective(s). Any changes in the Client’s financial situation or investment objectives reported by the Client to the Advisor shall be communicated to the independent manager(s) within a reasonable period of time.

A. Portfolio Manager Selection The Advisor may allocate a portion of a Client’s Program assets among unaffiliated independent investment managers and/or separately managed accounts in accordance with the Client’s designated investment objective(s). In such situations, the independent manager(s) or separately managed account managers shall have day-to-day responsibility for the active discretionary management of the allocated Program assets. The Advisor shall continue to render investment supervisory services to the Client relative to the ongoing monitoring and review of account performance, asset allocation and Client investment objectives. Factors which the Advisor shall consider in recommending independent manager(s) or separately managed accounts include the Client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. B. Related Persons The Advisor acts as the portfolio manager for the Program. Inasmuch as the execution costs for transactions effected in the Client account(s) will be paid by the Advisor, a conflict of interest arises in that the Advisor may have a disincentive to trade securities in the Client’s account(s). In addition, the amount of compensation received by the Advisor as a result of the Client’s participation in the Program may be more than what the Advisor would receive if the Client paid separately for investment advice, brokerage and other services. When managing a Client’s account(s) on a wrap fee basis, the Advisor shall receive as payment for its investment advisory services, the balance of the wrap fee after all other costs (including account transaction fees) incorporated into the wrap fee have been deducted. Accordingly, the Advisor has a conflict of interest because it could have an economic incentive to maximize its compensation by seeking to minimize the number of transactions/total costs or selecting mutual funds with no transaction fee in the Client's account(s). C. Supervised persons As discussed below, the Advisor also offers to its Clients, discretionary and/or nondiscretionary investment advisory services, on a non-wrap fee basis, as well as, Financial Planning and Consulting on a stand-alone basis. OTHER ADVISORY BUSINESS SERVICES INVESTMENT MANAGEMENT ON A NON-WRAP FEE BASIS

With regard to new clients, the Advisor solely offers discretionary and/or non-discretionary investment advisory services on a non-wrap fee basis. The Advisor’s annual investment advisory fee (up to 1.50%), shall be charged quarterly in advance, depending upon the level of Client assets managed by the Advisor;

and or the overall relationship. The Advisor, at its sole discretion, may offer a schedule that differs from the schedule herein. Please see Item 5 of the Disclosure Brochure for additional details. Alternatively, the Advisor may offer its non-wrap investment management services on a flat fee basis. To the extent offered, the Advisor’s flat fee for non-wrap investment management services will be based upon various subjective and objective factors Advisor's annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the Client, financial planning and consulting services. In the event that the Client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of the Advisor), the Advisor may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the Client. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE BASIS)

The Advisor may be engaged to provide a Client with a one-time financial plan without ongoing investment management services on a stand-alone separate fee basis. Prior to engaging the Advisor to provide planning or consulting services, Clients are generally required to enter into a Financial Planning and Consulting Agreement with the Advisor setting forth the terms and conditions of the engagement describing the scope of the services to be provided, and the portion of the fee that is due from the Client prior to the Advisor commencing services. If requested by the Client, the Advisor may recommend the services of other professionals, including certain of the Advisor’s representatives in their individual capacities as registered representatives of a brokerdealer, (See disclosure at Item 9) for implementation purposes. The Client is under no obligation to engage the services of any such recommended professional. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Advisor. If the Client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not the Advisor, shall be responsible for the quality and competency of the services provided. It remains the Client’s responsibility to promptly notify the Advisor if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Advisor’s previous recommendations and/or services. MISCELLANEOUS ADVISORY SERVICES DISCLOSURE

Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a Client, Advisor may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Advisor does not serve as an attorney or accountant, and no portion of its services should be construed aslegal or accounting services. Accordingly, Advisor does not prepare estate planning documents or tax returns. To the extent requested by a Client, Advisor may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance agents, etc.), including representatives of Advisor in their separate individual capacities as representatives Summit Trail Securities, LLC, an affiliated SEC registered and FINRA Member broker-dealer (“STS”). The Client is under no obligation to engage the services of any such recommended professional. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Advisor or its representatives.

If the Client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not the Advisor, shall be responsible for the quality and competency of the services provided. The recommendation by Advisors’ representatives that a Client purchase a securities commission product through Advisors’ representative in their separate and individual capacities as a registered representative of STS, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment products based on commissions to be received, rather than on the Client’s needs. No Client is under any obligation to purchase any securities commission products from an Advisor’s representative or to utilize the broker-dealer services of STS. Clients are reminded that they may purchase securities products recommended by Advisor through other, non-affiliated registered representatives and/or broker-dealers. Private Fund Investments - The Advisor may provide investment advice regarding affiliated and unaffiliated private investment funds.

Unaffiliated Funds - The Advisor’s role relative to any unaffiliated private investment fund shall be limited to its initial and ongoing due diligence and investment monitoring services. If a Client determines to become an investor in an unaffiliated private fund, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee (unless the Client purchases the fund from the Advisor’s affiliated broker-dealer). The Advisor’s Clients are under no obligation to consider or make an investment in an unaffiliated private investment fund(s). Affiliated Funds - The Adviser is the General Partner and/or Investment Advisor to various private funds issued by Ascent Private Capital Management (the Affiliated Fund[s]). If a Client determines to invest in an Affiliated Fund, the amount of assets invested in the Affiliated Fund shall be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee. The Advisor’s Clients are under no obligation to consider or make an investment in an Affiliated Fund. The Advisor does not receive a separate advisory fee or other forms of compensation for its investment advisory services to any Affiliated Funds. Rather, the Advisor’s only compensation is the advisory fee that it receives from any value included as a part of assets under management. Advisory Arrangements. Advisor may introduce Clients to private investment funds for which its serves as a sub-adviser. Advisor does not receive a separate sub-advisory fee for its sub-advisory services to the fund, nor any other type compensation from the fund. Rather, Advisor’s only compensation is the advisory fee that it receives from the Client as discussed above at Fees and Compensation. However, in the event that STS serves in a broker-dealer capacity for such funds, STS shall receive commission compensation. STS/Commission Purchases-The Advisor generally recommends private investment funds on a fee basis rather than on a commission basis through STS. STS will be recommended only when the Client prefers to pay a one-time commission to STS rather than an ongoing advisory fee to Advisor to monitor and review the fund on an ongoing basis.

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A. The Advisor has not been the subject of any disciplinary actions. Other Financial Activities and Affiliations Registered Representative of Summit Trail Securities, LLC. Certain Advisory Persons of the Advisor are also registered representatives of Summit Trail Securities, LLC (“STS”), an SEC registered and FINRA member broker-dealer. Neither the Advisor, nor its Advisory Persons, are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a representative of the foregoing. Registered Representatives of an Affiliated Broker Dealer. As disclosed above, certain Advisory Persons of the Adviser are also registered representatives of STS, an affiliated SEC registered and FINRA member broker-dealer. Clients can choose to engage an Advisory Person, and/or other related persons of STS in their individual capacities as registered representatives of STS, to effect securities brokerage transactions on a commission basis. Conflict of Interest: The recommendation by an Advisory Person or a related person of STS, that a Client

purchase a securities commission product presents a conflict of interest, as the receipt of commissions may

provide an incentive to recommend investment products based on commissions received, rather than on a particular Client’s need. No Client is under any obligation to purchase any commission products from an Advisory Person or through the Advisors’ affiliated broker-dealer, STS. Clients are reminded that they may purchase securities products recommended by the Advisor through other, non-affiliated registered representatives of a broker-dealer and through other non-affiliated broker-dealers. The Advisor’s Chief Compliance Officer, Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding the above conflicts of interest. Dynasty Financial Partners, LLC Affiliation The Advisor maintains a business relationship with Dynasty, which provides the Advisor with operational and back office support including access to a network of service providers. Through the Dynasty network of service providers, the Advisor has access to discounts on trading technology, reporting, custody, brokerage, compliance and other related services. While the Advisor believes this open architecture structure for operational services best serves the interests of its advisory Clients, this relationship may present certain conflicts of interest due to the fact that Dynasty retains a portion of the platform or other third party fees paid by the Advisor or Clients for the services referenced above. In light of the foregoing, the Advisor seeks at all times to ensure that any material conflicts are disclosed and handled in a manner that is aligned with its Clients’ best interests. The Advisor does not receive any portion of the fees paid directly to Dynasty, its affiliates or the service providers made available through Dynasty’s platform. In addition, the Advisor reviews all such relationships, including the service providers engaged through Dynasty, on an ongoing basis in an effort to ensure Clients are receiving competitive rates in relation to the quality and scope of the services provided. Dynasty’s subsidiary, Dynasty Wealth Management, LLC (“DWM”), a registered investment advisor, also provides access to a range of investment services, including separately managed accounts (“SMAs”), mutual fund and exchange-traded fund (“ETF”) asset allocation strategies and unified managed accounts (“UMAs”) managed by external third party managers (collectively the “Investment Programs”). The Advisor may receive more advantageous pricing as assets increase, which poses a conflict of interest with the Client. In light of the foregoing, the Advisor seeks at all times to determine that any such conflicts are addressed on a fully-disclosed basis and investment decisions are handled in a manner that is aligned with its Clients’ best interests. Summit Trail does not receive any portion of the fees paid directly to Dynasty or the service providers made available through its platform, and the Summit Trail reviews all such relationships on an ongoing basis in an effort to ensure Clients are receiving competitive rates in light of the services they receive. The Advisor has obtained financing for its business through Dynasty Advisors Financing Services, LLC (“DAFS”), a wholly-owned subsidiary of Dynasty Financial Partners, LLC (and affiliate of Dynasty Wealth Management, LLC). DAFS, in partnership with various independent banks, has provided the Advisor with a lending facility to assist with business transition expenses and other costs associated with launching the Advisor. The Advisor is not obligated to utilize the DAFS lending facility in order to obtain other services from Dynasty. All lending is subject to standard underwriting requirements. A portion of this loan may be furnished directly from Dynasty as a co- lender. In such situations, the Advisor will be subject to the same lending facility criteria and requirements as applied by the independent bank. Insurance Company. The Advisor is a licensed insurance agency, and as such, may offer insurance products on a commission basis. The Advisor shall generally introduce the Client to an unaffiliated insurance agency to manage the insurance process. The Advisor shall receive a portion of the insurance commission earned

by the unaffiliated insurance agency. No Client shall be under any obligation to purchase any insurance products from the Advisor or such introduced insurance agency. The recommendation by an Advisory Person that a Client purchase an insurance product presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than based on a particular Client’s need. Clients are reminded that they remain free to purchase insurance products through other insurance agencies. Non-Soft Dollar Research and Additional Benefits Although not a material consideration when determining whether to recommend that a Client utilize the services of a particular broker-dealer/custodian, the Advisor receives from IB, Pershing, Fidelity, and/or Schwab without cost (and/or at a discount) support services and/or products, certain of which assist the Advisor to better monitor and service Client accounts maintained at such institutions. Included within the support services that may be obtained by the Advisor may be investment-related research, pricing information and market data, software and other technology that provide access to Client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by Advisor in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products received may assist the Advisor in managing and administering Client accounts. Others do not directly provide such assistance, but rather assist the Advisor to manage and further develop its business enterprise. There is no corresponding commitment made by the Advisor to IB, Pershing, Fidelity or Schwab, or any other entity, to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. Additional Benefits Advisor has received from Pershing and Fidelity, certain additional economic benefits, related to business development needs, (“Additional Benefits”) that may or may not be offered to Advisor again in the future. Specifically, the Additional Benefits include partial payment for certain research and technology expenses for the benefit of the Advisor. Over the past two years, Pershing has made payments to third party vendors for technology and research related expenses. Pershing and Fidelity has made one off payments between $1,000 and $25,000 infrequently and irregularly to these third party service providers over the course of the last two years. Each payment is non-recurring and individually negotiated. The Advisor has no expectation that these Additional Benefits will be offered again; however, Advisor reserves the right to negotiate for these Additional Benefits in the future. Pershing and Fidelity provides the Additional Benefits to Advisor in its sole discretion and at its own expense, and neither the Advisor nor its Clients pay any fees to Pershing for the Additional Benefits. The Advisor and Pershing and/or Fidelity has entered into any written agreement to govern the Additional Benefits. B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information The Advisor maintains a Code of Ethics that is applicable to all individuals associated with Summit Trail (our “Supervised Persons”). In addition, the Advisor maintains an investment policy relative to personal securities transactions for Supervised Persons with access to Client investment information (our “Access Persons”). This investment policy is part of the Advisor’s overall Code of Ethics, which serves to establish astandard of business conduct that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request.

In accordance with Section 204A of the Advisers Act, the Advisor also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by the Advisor or any Supervised Person. As disclosed above, the Advisor may recommend participation in initial and secondary offerings to eligible Clients. In such cases, offerings may be available in limited quantities wherein the Advisor may need to allocate shares to Clients in a lesser proportion than as requested by the Client. These situations create a conflict of interest and in such cases the Advisor will manage such conflicts through applicable policies and procedures. As disclosed above, related persons have a financial interest in the affiliated private funds. The terms and conditions for participation in each affiliated private fund, including management fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents. The Advisor and/or its Access Persons may buy or sell securities that are also recommended to Clients. This practice may create a situation where the Advisor and/or its Access Persons are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that security for investment and then immediately sells it at a profit upon the rise in the market price which follows the recommendation) could take place if the Advisor did not have adequate policies in place to detect such activities. In addition, this requirement can help detect insider trading, “front-running” (i.e., personal trades executed prior to those of the Advisor’s Clients) and other potentially abusive practices. The Advisor has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of the Advisor’s “Access Persons”. The Advisor’s securities transaction policy requires that an Access Person of the Advisor must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide or make available to the Chief Compliance Officer or his/her designee a list of reportable transactions each calendar quarter as well as a written annual report of the Access Person’s securities holdings; provided, however that at any time that the Advisor has only one Access Person, he or she shall not be required to submit any securities report described above. The Advisor and/or its Access Persons may buy or sell securities, at or around the same time as those securities are recommended to Clients. This practice creates a situation where the Advisor and/or its Access Persons are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. The Advisor has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of Advisor’s Access Persons. Review of Accounts For those Clients to whom Advisor provides investment supervisory services, account reviews are conducted on an ongoing basis by the Advisor's Principals. All investment supervisory Clients are advised that it remains their responsibility to advise the Advisor of any changes in their investment objectives and/or financial situation. All Clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives and account performance with the Advisor on an annual basis.

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