Common use of Execution of Brokerage Transactions Clause in Contracts

Execution of Brokerage Transactions. Unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who we reasonably believe will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below). We shall not favor any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involved. Transactions for each client account will sometimes be effected independently, but more often we expect to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstances.

Execution of Brokerage Transactions. Unless directed otherwise(when applicable). If requested, we ADVISER will arrange for the execution of securities brokerage transactions for the Assets Account through Fidelity who we broker-dealers that ADVISER reasonably believe believes will provide “best execution”. In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Brokera broker-Dealer’s dealer‟s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we ADVISER will seek competitive commission rates, we it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions for the Account may be effected through broker-dealers in return for research products and/or services which assist ADVISER in its investment decision making process. Such research generally will be used to service all of ADVISER‟s clients (see Exhibit A belowincluding accounts that may not generate commissions used to pay for investment research), but brokerage commissions paid by CLIENT may be used to pay for research that is not used in managing the Account. We shall not favor any account over any other The Account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines in good faith that the commission is reasonable in relation to the value of the brokerage and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedresearch services received. Transactions for each client account generally will sometimes be effected independently, but more often we expect unless ADVISER decides to purchase or sell the same securities for several separate account clients at approximately the same time. We ADVISER may (but are is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, rates or to allocate equitably among our ADVISER‟s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our ADVISER‟s clients in proportion to the purchase and sale orders placed for each client account on any given day. To The CLIENT may direct ADVISER to use a particular broker-dealer to execute some or all transactions for the extent Account (subject to ADVISER‟s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that we aggregate client broker-dealer, and ADVISER will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISER. As a result, the purchase CLIENT correspondingly acknowledges that such direction may cause the Account to incur higher commission or sale of securities we shall do so in accordance with applicable rules promulgated under transaction costs than the Advisers Act and no-action guidance provided by Account would otherwise incur had the staff of the Securities and Exchange Commission. We shall endeavor CLIENT determined to process all effect Account transactions in through alternative arrangements that may be available through the ADVISER. In the event that the transactions for the Account are effected through a timely mannerbroker-dealer that refers investment management clients to ADVISER, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion potential for conflict of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstancesinterest may arise.

Execution of Brokerage Transactions. Unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who we reasonably believe will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below). We shall not favor any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involved. Transactions for each client account will sometimes be effected independently, but more often we expect to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity or Schwab under any circumstances.

Execution of Brokerage Transactions. Unless For Assets directly managed by us, unless directed otherwise, we will arrange for the transaction and execution of securities brokerage transactions for the Assets through Fidelity who a broker-dealer that we reasonably believe will provide “best execution”. .” In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions. Certain of our Investment Adviser Representatives are also registered representatives of FINRA member Broker Dealers including ACM’s affiliated entity Aventura Securities, LLC and are subject to FINRA Rule 3040 which restricts registered representatives from conducting securities transactions (see Exhibit A below)away from their broker-dealer written consent. We shall not favor any account over any other and purchase Therefore, clients are advised that certain Investment Adviser Representatives registered with Aventura Securities, LLC may be restricted to conducting securities transactions through Aventura Securities, LLC unless they first secure written consent from Aventura Securities, LLC to execute securities transactions though a different broker-dealer. Absent such written consent or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involved. Transactions for each client account will sometimes be effected independentlyseparation from Aventura Securities, but more often we expect to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best executionLLC, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities we shall do so in accordance with applicable these Investment Advisor rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to process all Account account transactions in a timely manner, but do not represent nor or warrant that any such transaction shall be processed or effected by Fidelity the Broker-Dealer on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstances.

Execution of Brokerage Transactions. Unless directed otherwiseIf requested, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who a broker-dealer that we reasonably believe will provide “best execution”. .” In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below)transactions. We shall endeavor to process all Account transactions in a timely manner, but do not favor warrant or represent that any account over any other and purchase or sale orders executed contemporaneously such transaction shall be allocated effected on the same day as requested. Consistent with obtaining best execution, transactions for your Account may be directed to registered broker-dealers in return for research products and/or services that assist us in our investment decision- making process. Such research generally will be used to service all of our clients, but brokerage commissions paid by you may be used to pay for research that is not used in managing your Account. Thus, you may pay the Broker-Dealer a manner greater commission than another qualified broker-dealer might charge to effect the same transaction where we deem equitable among determine in good faith that the accounts involvedcommission is reasonable in relation to the value of the brokerage and research services received. Transactions for each client account generally will sometimes be effected independently, but more often unless we expect decide to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities, including securities in which persons associated with us (as defined in the Advisers Act; hereafter “Associated Person(s)”) may invest, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion additional compensation or remuneration as a result of the brokerage aggregation. You may direct us in writing to use a particular broker-dealer (“Directed Broker”) to execute some or all transactions for your Account (referred to as “directed brokerage”). In that case, you will have the sole responsibility to negotiate terms and arrangements for the Account with the Directed Broker and we will not seek better execution services or prices from other broker-dealers or be able to “batch” transactions for execution through other broker-dealers with orders for other accounts we manage. As a result, you may pay higher commissions and/or or other transaction fees charged costs, greater spreads, or receive less favorable net prices be responsible for (i) those assets that you have not designated to you by Fidelity be the subject of our investment management services under any circumstancesthis Agreement; or (ii) proper diversification of all of your assets.

Execution of Brokerage Transactions. Unless directed For Accounts other than those managed by Independent Managers, unless you direct us otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who a broker-dealer that we reasonably believe will provide “best execution”. .” In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions (see Exhibit A below)for your Account may be directed to registered broker-dealers in return for research products and/or services that assist us in our investment decision-making process. We shall Such research generally will be used to service all of our clients, but brokerage commissions paid by you may be used to pay for research that is not favor any account over any other used in managing your Account. Thus, you may pay the Broker-Dealer a greater commission than another qualified broker-dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedresearch services received. Transactions for each client account generally will sometimes be effected independently, but more often unless we expect decide to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities, including securities in which our Advisory Affiliates may invest, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity the Broker-Dealer on the same day as requested. We You may direct us in writing to use a particular broker-dealer (“Directed Broker”) to execute some or all transactions for your Account (referred to as “directed brokerage”). In that case, you will have the sole responsibility to negotiate terms and arrangements for the Account with the Directed Broker and we will not seek better execution services or prices from other broker-dealers or be able to “batch” transactions for execution through other broker-dealers with orders for other accounts we manage. As a result, you may pay higher commissions or other transaction costs, greater spreads, or receive any portion of less favorable net prices on transactions for the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstancesAccount than would otherwise be the case.

Execution of Brokerage Transactions. Unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity Fidelity, Schwab, or JPM, depending on where your account is located, who we reasonably believe will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below). We shall not favor any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involved. Transactions for each client account will sometimes be effected independently, but more often we expect to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity Fidelity, Schwab, or JPM, as the case may be, under any circumstances.

Execution of Brokerage Transactions. Unless directed otherwise(when applicable). If requested, we Advisor will arrange for the execution of securities brokerage transactions for the Assets Account through Fidelity who we Broker-Dealers that Advisor reasonably believe believes will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the a Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions (see Exhibit A below)for the Account may be effected through Broker-Dealers in return for research products and/or services which assist Advisor in its investment decision making process. We shall Such research generally will be used to service all of Advisor’s Clients, but brokerage commissions paid by Client may be used to pay for research that is not favor any account over any other used in managing the Account. The Account may pay to a Broker-Dealer a commission greater than another qualified Broker-Dealer might charge to effect the same transaction where Advisor determines in good faith that the commission is reasonable in relation to the value of the brokerage and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedresearch services received. Transactions for each client Client account generally will sometimes be effected independently, but more often we expect unless Advisor decides to purchase or sell the same securities for several separate account clients Clients at approximately the same time. We Advisor may (but are is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, rates or to allocate equitably among our clients Advisor’s Clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients Advisor’s Clients in proportion to the purchase and sale orders placed for each client Client account on any given day. To the extent that we the Advisor determines to aggregate client Client orders for the purchase or sale of securities, including securities we in which Advisor’s principal(s) and/or associated person(s) may invest, the Advisor shall generally do so in accordance with applicable rules promulgated under the Advisers Act and noparameters set forth in SEC No-action guidance provided by the staff of the Securities and Exchange CommissionAction Letter. We The Advisor shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion additional compensation or remuneration as a result of the brokerage aggregation. The Client may direct Advisor to use a particular Broker-Dealer to execute some or all transactions for the Account (subject to Adviser’s right to decline and/or terminate the engagement). In such event, the Client will negotiate terms and arrangements for the Account with that Broker-Dealer, and Advisor will not seek better execution services or prices from other Broker-Dealers or be able to “batch” Client transactions for execution through other Broker-Dealers with orders for other accounts managed by Advisor. As a result, Client may pay higher commissions and/or or other transaction fees charged costs or greater spreads, or receive less favorable net prices, on transactions for the Account than would otherwise be the case. In the event that the transactions for the Account are effected through a Broker-Dealer that refers investment management Clients to you by Fidelity under any circumstancesthe Advisor, the potential for conflict of interest may arise.

Execution of Brokerage Transactions. Unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who a broker-dealer that we reasonably believe will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions. Neither we, nor any of our Advisory Affiliates (as defined in Form ADV), will receive any portion of the brokerage commissions and/or transaction fees charged to you by the Broker-Dealer. Consistent with obtaining best execution, transactions (see Exhibit A below)for your Account may be directed to registered broker-dealers in return for research products and/or services that assist us in our investment decision-making process. We shall Such research generally will be used to service all of our clients, but brokerage commissions paid by you may be used to pay for research that is not favor any account over any other used in managing your Account. Thus, you may pay the Broker-Dealer a greater commission than another qualified broker- dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedresearch services received. Transactions for each client account generally will sometimes be effected independently, but more often unless we expect decide to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities, including securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff which our Advisory Affiliates may success of our overall management of the Securities Account. You understand that our investment decisions made for your Account are subject to various market, currency, economic, political and Exchange Commission. We shall endeavor to process all Account transactions in a timely mannerbusiness risks, but do not represent nor warrant and that any such transaction shall be processed or effected by Fidelity on the same day as requested. We those investment decisions will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstancesalways be profitable.

Execution of Brokerage Transactions. Unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who we reasonably believe will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below). We shall not favor any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involved. Transactions for each client account will sometimes be effected independently, but more often we expect to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstances.. _______________________________________________

Execution of Brokerage Transactions. Unless directed otherwise(when applicable). If requested, we ADVISER will arrange for the execution of securities brokerage transactions for the Assets Account through Fidelity who we broker-dealers that ADVISER reasonably believe believes will provide “best execution”. In seeking ‘best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Brokera broker-Dealerdealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we ADVISER will seek competitive commission rates, we it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions for the Account may be effected through broker-dealers in return for research products and/or services which assist ADVISER in its investment decision making process. Such research generally will be used to service all of ADVISER’s clients (see Exhibit A belowincluding accounts that may not generate commissions used to pay for investment research), but brokerage commissions paid by CLIENT may be used to pay for research that is not used in managing the Account. We shall not favor any account over any other The Account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines in good faith that the commission is reasonable in relation to the value of the brokerage and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedresearch services received. Transactions for each client account generally will sometimes be effected independently, but more often we expect unless ADVISER decides to purchase or sell the same securities for several separate account clients at approximately the same time. We ADVISER may (but are is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, rates or to allocate equitably among our ADVISER’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our ADVISER’s clients in proportion to the purchase and sale orders placed for each client account on any given day. To The CLIENT may direct ADVISER to use a particular broker-dealer to execute some or all transactions for the extent Account (subject to ADVISER’s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that we aggregate client broker-dealer, and ADVISER will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISER. As a result, the purchase CLIENT correspondingly acknowledges that such direction may cause the Account to incur higher commission or sale of securities we shall do so in accordance with applicable rules promulgated under transaction costs than the Advisers Act and no-action guidance provided by Account would otherwise incur had the staff of the Securities and Exchange Commission. We shall endeavor CLIENT determined to process all effect Account transactions in through alternative arrangements that may be available through the ADVISER. In the event that the transactions for the Account are effected through a timely mannerbroker-dealer that refers investment management clients to ADVISER, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion potential for conflict of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstancesinterest may arise.

Execution of Brokerage Transactions. Unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who we reasonably believe will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s Custodians’ services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below)transactions. We shall will not favor receive any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among portion of the accounts involvedbrokerage commissions and/or transaction fees charged to you by the Custodian. Transactions for each client account generally will sometimes be effected independently, but more often unless we expect decide to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices price and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to process all Account transactions in a timely manner, but do not neither represent nor warrant that any such transaction shall be processed or effected by Fidelity the Broker-Dealer on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstances.

Execution of Brokerage Transactions. Unless directed otherwiseIf requested, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who a broker-dealer that we reasonably believe will provide “best execution”. .” In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below)transactions. We shall endeavor to process all Account transactions in a timely manner, but do not favor warrant or represent that any account over any other and purchase or sale orders executed contemporaneously such transaction shall be allocated effected on the same day as requested. Consistent with obtaining best execution, transactions for your Account may be directed to registered broker-dealers in return for research products and/or services that assist us in our investment decision- making process. Such research generally will be used to service all of our clients, but brokerage commissions paid by you may be used to pay for research that is not used in managing your Account. Thus, you may pay the Broker-Dealer a manner greater commission than another qualified broker-dealer might charge to effect the same transaction where we deem equitable among determine in good faith that the accounts involvedcommission is reasonable in relation to the value of the brokerage and research services received. Transactions for each client account generally will sometimes be effected independently, but more often unless we expect decide to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities, including securities in which persons associated with us (as defined in the Advisers Act; hereafter “Associated Person(s)”) may invest, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion additional compensation or remuneration as a result of the brokerage aggregation. You may direct us in writing to use a particular broker-dealer (“Directed Broker”) to execute some or all transactions for your Account (referred to as “directed brokerage”). In that case, you will have the sole responsibility to negotiate terms and arrangements for the Account with the Directed Broker and we will not seek better execution services or prices from other broker-dealers or be able to “batch” transactions for execution through other broker-dealers with orders for other accounts we manage. As a result, you may pay higher commissions and/or or other transaction fees charged to you by Fidelity under any circumstancescosts, greater spreads, or receive less favorable net prices on transactions for the Account than would otherwise be the case.

Execution of Brokerage Transactions. Unless directed otherwise(when applicable). If requested, we Adviser will arrange for the execution of securities brokerage transactions for the Assets Account through Fidelity who we Broker-Dealers that Adviser reasonably believe believes will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-a Broker- Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we Adviser will seek competitive commission rates, we it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions (see Exhibit A below)for the Account may be effected through Broker-Dealers in return for research products and/or services which assist Adviser in its investment decision making process. We shall Such research generally will be used to service all of Adviser’s Clients, but brokerage commissions paid by Client may be used to pay for research that is not favor any account over any other used in managing the Account. The Account may pay to a Broker-Dealer a commission greater than another qualified Broker-Dealer might charge to effect the same transaction where Adviser determines in good faith that the commission is reasonable in relation to the value of the brokerage and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedresearch services received. Transactions for each client Client account generally will sometimes be effected independently, but more often we expect unless Adviser decides to purchase or sell the same securities for several separate account clients Clients at approximately the same time. We Adviser may (but are is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, rates or to allocate equitably among our clients Adviser’s Clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients Adviser’s Clients in proportion to the purchase and sale orders placed for each client Client account on any given day. To the extent that we the Adviser determines to aggregate client Client orders for the purchase or sale of securities, including securities we in which Adviser’s principal(s) and/or associated person(s) may invest, the Adviser shall generally do so in accordance with applicable rules promulgated under the Advisers Act and noparameters set forth in SEC No-action guidance provided by the staff of the Securities and Exchange Commission. We Action Letter, SMC Capital, Inc. The Adviser shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion additional compensation or remuneration as a result of the brokerage aggregation. The Client may direct Adviser to use a particular Broker-Dealer to execute some or all transactions for the Account (subject to Adviser’s right to decline and/or terminate the engagement). In such event, the Client will negotiate terms and arrangements for the Account with that Broker-Dealer, and Adviser will not seek better execution services or prices from other Broker-Dealers or be able to “batch” Client transactions for execution through other Broker- Dealers with orders for other accounts managed by Adviser. As a result, Client may pay higher commissions and/or or other transaction fees charged costs or greater spreads, or receive less favorable net prices, on transactions for the Account than would otherwise be the case. In the event that the transactions for the Account are effected through a Broker-Dealer that refers investment management Clients to you by Fidelity under any circumstancesthe Adviser , the potential for conflict of interest may arise.

Execution of Brokerage Transactions. Unless directed otherwise, we will You direct us to arrange for the execution of securities brokerage transactions for the Assets through Fidelity Fidelity, who we reasonably believe will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below)transactions. We shall not favor any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involved. Transactions for each client account will sometimes be effected independently, but more often we expect to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine aggregate or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedureWhen we aggregate orders as a block trade, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstances.

Execution of Brokerage Transactions. Unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who we reasonably believe will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions (see Exhibit A below). We shall not favor any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involved. Transactions for each client account will sometimes be effected independently, but more often we expect to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstances. your account. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor.

Execution of Brokerage Transactions. Unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets in your Accounts through Fidelity who a broker-dealer that we reasonably believe will provide “best execution”.” This may include placing trades with broker-dealers with whom you have entered into arrangements for prime brokerage clearing services. In this event, you will incur both the transaction fee charged by the executing broker-dealer and a “trade-away” fee charged by your Custodian. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Brokerbroker-Dealerdealer’s services including the value of research providedincluding, but not limited to, execution capability, commission ratesrates and/or transaction fees, and responsiveness. Accordingly, although we will seek competitive commission ratesrates and/or transaction fees, we may not necessarily obtain the lowest possible commission rates for Account account transactions. Consistent with obtaining best execution, transactions (see Exhibit A below)in your Accounts may be directed to registered broker-dealers in return for research products and/or services that assist us in our investment decision- making process. We shall may authorize the payment of higher commissions and/or trading costs by your Accounts than those that may be otherwise available if we determine in good faith that the amount of such commission cost is reasonable in relation to the value of the research products and/or services provided by the broker-dealer. Such research products and/or services generally will be used to service all of our clients, but brokerage commissions paid by you may be used to pay for research products and/or services that are not favor any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedused for your Account. Transactions for each client account generally will sometimes be effected independently, but more often unless we expect decide to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given block that may occur in a given day. To the extent that we aggregate client orders for the purchase or sale of securities, including securities in which our Advisory Affiliates may invest, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to process all Account account transactions in a timely manner, but do not neither represent nor warrant that any such transaction shall be processed or effected by Fidelity the broker-dealer on the same day as requested. We will not receive any portion of the If you choose to direct brokerage commissions and/or transaction fees charged for your Accounts, you should review our Form ADV, Part 2A for important information relating to you by Fidelity under any circumstancesdirected brokerage.

Execution of Brokerage Transactions. Unless As previously mentioned, we are your Financial Strategists and, as such, are responsible for managing the relationship between you and the Custodian of the assets (Altruist) and managing your investment portfolio. As such and unless directed otherwise, we will arrange for the execution of securities brokerage transactions for the Assets through Fidelity who a broker- dealer that we reasonably believe will provide “best execution”. .” In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the Broker-Dealer’s 's services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive commission rates, we may not necessarily obtain the lowest possible commission rates for Account transactions. Neither we, nor any of our Associated Persons, will receive any portion of the brokerage commissions and/or transaction fees charged to you by the Broker-Dealer. Consistent with obtaining best execution, transactions (see Exhibit A below)for your Account may be directed to registered broker-dealers in return for research products and/or services that assist us in our investment decision-making process. We shall Such research generally will be used to service all of our clients, but brokerage commissions paid by you may be used to pay for research that is not favor any account over any other used in managing your Account. Thus, you may pay the Broker-Dealer a greater commission than another qualified broker-dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedresearch services received. Transactions for each client account generally will sometimes be effected independently, but more often effectuated independently unless we expect decide to purchase or sell the same securities for several separate account clients at approximately the same time. We may (but are not obligated to) combine or “batch” such orders to obtain best execution, negotiate more favorable commission rates, or allocate equitably among our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. To the extent that we aggregate client orders for the purchase or sale of securities, including securities in which persons associated with us (as defined in the Advisers Act, hereafter “Associated Person(s)”) may invest, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor or warrant that any such transaction shall be processed or effected by Fidelity the Broker-Dealer on the same day as requested. We will not receive any portion of the brokerage commissions and/or transaction fees charged to you by Fidelity under any circumstances.

Execution of Brokerage Transactions. Unless directed otherwise(when applicable). If requested, we Adviser will arrange for the execution of securities brokerage transactions for the Assets Account through Fidelity who we Broker-Dealers that Adviser reasonably believe believes will provide “best execution”. In seeking best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the a Broker-Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we Adviser will seek competitive commission rates, we it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions (see Exhibit A below)for the Account may be effected through Broker-Dealers in return for research products and/or services which assist Adviser in its investment decision making process. We shall Such research generally will be used to service all of Adviser’s Clients, but brokerage commissions paid by Client may be used to pay for research that is not favor any account over any other used in managing the Account. The Account may pay to a Broker-Dealer a commission greater than another qualified Broker-Dealer might charge to effect the same transaction where Adviser determines in good faith that the commission is reasonable in relation to the value of the brokerage and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the accounts involvedresearch services received. Transactions for each client Client account generally will sometimes be effected independently, but more often we expect unless Adviser decides to purchase or sell the same securities for several separate account clients Clients at approximately the same time. We Adviser may (but are is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates, rates or to allocate equitably among our clients Adviser’s Clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among our clients Adviser’s Clients in proportion to the purchase and sale orders placed for each client Client account on any given day. To the extent that we the Adviser determines to aggregate client Client orders for the purchase or sale of securities, including securities we in which Adviser’s principal(s) and/or associated person(s) may invest, the Adviser shall generally do so in accordance with applicable rules promulgated under the Advisers Act and noparameters set forth in SEC No-action guidance provided by the staff of the Securities and Exchange Commission. We Action Letter, The Adviser shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by Fidelity on the same day as requested. We will not receive any portion additional compensation or remuneration as a result of the brokerage aggregation. The Client may direct Adviser to use a particular Broker-Dealer to execute some or all transactions for the Account (subject to Adviser’s right to decline and/or terminate the engagement). In such event, the Client will negotiate terms and arrangements for the Account with that Broker-Dealer, and Adviser will not seek better execution services or prices from other Broker-Dealers or be able to “batch” Client transactions for execution through other Broker-Dealers with orders for other accounts managed by Adviser. As a result, Client may pay higher commissions and/or or other transaction fees charged costs or greater spreads, or receive less favorable net prices, on transactions for the Account than would otherwise be the case. In the event that the transactions for the Account are effected through a Broker-Dealer that refers investment management Clients to you by Fidelity under any circumstancesthe Adviser, the potential for conflict of interest may arise.