Common use of Types of Clients Clause in Contracts

Types of Clients. Confluence provides portfolio management services to individuals (including high net worth individuals) and entities such as financial institutions (on behalf of their clients), corporations and corporate pension and profit-sharing plans, Xxxx-Xxxxxxx plans, other investment advisers (on behalf of their clients), charitable institutions, foundations, endowments, municipalities, and registered investment companies. Confluence generally requires Advisor Based accounts (which are generally single contract or dual contract arrangements, including Wrap Account programs, offered through Financial Institutions) to have a minimum account value of $100,000 ($200,000 in the case of Balanced accounts and $50,000 for Asset Allocation strategies); Private Wealth accounts (which are generally high net worth individuals) to have a minimum account value of $500,000; and Institutional accounts to a have minimum account value of $5 million. Confluence allows firm personnel and their family members to maintain accounts that Confluence manages. Some Confluence employees also invest in the open-end mutual fund and closed-end fund that Confluence sub-advises. Confluence employees may suggest investment companies that Confluence sub-advises to certain clients. This presents a conflict of interest in that it could create an incentive for Confluence to favor these funds over other investment companies. Confluence maintains investment and trade allocation policies designed to manage such conflicts of interest. Item 8—Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Confluence employs fundamental and cyclical security analysis methods, which vary by the type of portfolio strategy provided. Confluence’s Equity strategies, which are comprised of common equity securities of companies, utilize a bottom-up, fundamental approach. Confluence’s Asset Allocation and Fixed Income strategies, and the fixed income portion of our Balanced accounts , are implemented using exchange-traded funds (“ETFs”), and utilize a top-down, cyclical approach. An ETF is an individual security that trades on an exchange and represents a basket of securities or other assets that are typically designed to track the performance of targeted indices, sectors or asset classes. The firm’s Global Hard Assets strategy, which is primarily comprised of common equity securities and a portion of ETFs, utilizes a combination of the above two approaches. Confluence also manages sector-specific strategies (e.g., Business Development Companies, Real Estate Investment Trusts and Utilities) that utilize both top-down and bottom-up approaches. For the Increasing Dividend Equity Account (“IDEA”) Plus strategy, which is an equity strategy combined with a covered call option strategy on the S&P 500 Index, the firm analyzes option securities for their strike price, premium, volatility and term. Approximately 75% of the portfolio is the IDEA portfolio of common equity securities, in which the stock selection utilizes qualitative analyses in an attempt to identify high-quality companies with long track records of distributing earnings to shareholders through dividends. The remaining 25% consists of an ETF position in the S&P 500 Index with a corresponding covered call position, although this allocation will fluctuate due to account size and/or the price of the Index. A substantial portion of investment research is generated in-house. Confluence also utilizes external research sources, such as Bloomberg, Xxxxx Analytics, Xxx Xxxxx, FactSet, Refinitiv and various governmental banking and agency data. Confluence will also utilize analytics from other private market research institutions.

Types of Clients. Confluence provides portfolio management services to individuals (including high net worth individuals) and entities such as financial institutions (on behalf of their clients), corporations and corporate pension and profit-sharing plans, Xxxx-Xxxxxxx plans, other investment advisers (on behalf of their clients), charitable institutions, foundations, endowments, municipalities, and registered investment companies. Confluence generally requires Advisor Based accounts (which are generally single contract or dual contract arrangements, including Wrap Account programs, offered through Financial Institutions) to have a minimum account value of $100,000 ($200,000 in the case of Balanced accounts strategies and $50,000 for Asset Allocation strategies); Private Wealth accounts (which are generally high net worth individuals) to have a minimum account value of $500,000; and Institutional accounts to a have minimum account value of $5 million. Confluence allows firm personnel and their family members to maintain accounts that Confluence manages. Some Confluence employees also invest in the open-end mutual fund and closed-end fund that Confluence sub-advises. Confluence employees may suggest recommend investment companies that Confluence sub-advises to certain clients. This presents a conflict of interest in that it could create an incentive for Confluence to favor these funds over other investment companies. Confluence maintains investment and trade allocation policies designed to manage such conflicts of interest. Item 8—Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Confluence employs fundamental and cyclical security analysis methods, which vary by the type of portfolio strategy provided. Confluence’s Equity strategies, which are comprised of common equity securities of companies, utilize a bottom-up, fundamental approach. Confluence’s Asset Allocation and Fixed Income strategies, and the fixed income portion of our Balanced accounts strategies, are implemented using exchange-traded funds (“ETFs”), and utilize a top-down, cyclical approach. An ETF is an individual security that trades on an exchange and represents a basket of securities or other assets that are typically designed to track the performance of targeted indices, sectors or asset classes. The firm’s Global Hard Assets strategy, which is primarily comprised of common equity securities and a portion of ETFs, utilizes a combination of the above two approaches. Confluence also manages sector-specific strategies (e.g., Business Development Companies, Real Estate Investment Trusts and Utilities) that utilize both top-down and bottom-bottom- up approaches. For the Increasing Dividend Equity Account (“IDEA”) Plus strategy, which is an equity strategy combined with a covered call option strategy on the S&P 500 Index, the firm analyzes option securities for their strike price, premium, volatility and term. Approximately 75% of the portfolio is the IDEA portfolio of common equity securities, in which the stock selection utilizes qualitative analyses in an attempt to identify high-quality companies with long track records of distributing earnings to shareholders through dividends. The remaining 25% consists of an ETF position in the S&P 500 Index with a corresponding covered call position, although this allocation will fluctuate due can range at times from 15% to account size and/or the price 40% of the Indexportfolio. A substantial portion of investment research is generated in-house. Confluence also utilizes external research sources, such as Bloomberg, Xxxxx Analytics, Xxx Xxxxx, FactSet, Refinitiv Advantage Data and various governmental banking and agency data. Confluence will also utilize analytics from other private market research institutions.

Types of Clients. Confluence provides portfolio management services to individuals (including high net worth individuals) and entities such as financial institutions (on behalf of their clients), corporations and corporate pension and profit-sharing plans, Xxxx-Xxxxxxx plans, other investment advisers (on behalf of their clients), charitable institutions, foundations, endowments, municipalities, and registered investment companies. Confluence generally requires Advisor Based accounts (which are generally single single-contract or dual dual-contract arrangements, including Wrap Account programs, offered through Financial Institutions) to have a minimum account value of $100,000 ($200,000 in the case of Balanced accounts and $50,000 for Asset Allocation strategies); Private Wealth accounts (which are generally high high-net worth individuals) to have a minimum account value of $500,000; and Institutional accounts to a have minimum account value of $5 million. Confluence allows firm personnel and their family members to maintain accounts that Confluence manages. Some Confluence employees also invest in the open-end mutual fund and closed-end fund that Confluence sub-advises. Confluence employees may suggest investment companies that Confluence sub-advises to certain clients. This presents a conflict of interest in that it could create an incentive for Confluence to favor these funds over other investment companies. Confluence maintains investment and trade allocation policies designed to manage such conflicts of interest. Item 8—Methods of Analysis, Investment Strategies Strategies, and Risk of Loss METHODS OF ANALYSIS Confluence employs fundamental and cyclical security analysis methods, which vary by the type of portfolio strategy provided. Confluence’s Equity strategies, which are comprised of common equity securities of companies, utilize a bottom-up, fundamental approach. Confluence’s Asset Allocation and Fixed Income strategies, and the fixed income portion of our Balanced accounts accounts, are implemented using exchange-traded funds (“ETFs”), ) and utilize a top-down, cyclical approach. An ETF is an individual security that trades on an exchange and represents a basket of securities or other assets that are typically designed to track the performance of targeted indices, sectors sectors, or asset classes. The firm’s Global Hard Assets strategy, which is primarily comprised of common equity securities and a portion of ETFs, utilizes a combination of the above two approaches. Confluence also manages sector-specific strategies (e.g., Business Development Companies, Real Estate Investment Trusts Trusts, and Utilities) that utilize both top-down and bottom-up approaches. For the Increasing Dividend Equity Account (“IDEA”) Plus strategy, which is an equity strategy combined with a covered call option strategy on the S&P 500 Index, the firm analyzes option securities for their strike price, premium, volatility volatility, and term. Approximately 75% of the portfolio is the IDEA portfolio of common equity securities, in which the stock selection utilizes qualitative analyses in an attempt to identify high-quality companies with long track records of distributing earnings to shareholders through dividends. The remaining 25% consists of an ETF position in the S&P 500 Index with a corresponding covered call position, although this allocation will fluctuate due to account size and/or the price of the Index. A substantial portion of investment research is generated in-house. Confluence also utilizes external research sources, such as Bloomberg, Xxxxx Analytics, Strategas, Morningstar, Xxx Xxxxx, FactSet, Refinitiv Refinitiv, and various governmental banking and agency data. Confluence will also utilize analytics from other private market research institutions.. INVESTMENT STRATEGIES – METHODOLOGY

Types of Clients. Confluence provides portfolio management services to individuals (including high net worth individuals) and entities such as financial institutions (on behalf of their clients), corporations and corporate pension and profit-sharing plans, Xxxx-Xxxxxxx plans, other investment advisers (on behalf of their clients), charitable institutions, foundations, endowments, municipalities, and registered investment companies. Confluence generally requires Advisor Based accounts (which are generally single contract or dual contract arrangements, including Wrap Account programs, offered through Financial Institutions) to have a minimum account value of $100,000 ($200,000 in the case of Balanced accounts strategies and $50,000 for Asset Allocation strategies); Private Wealth accounts (which are generally high net worth individuals) to have a minimum account value of $500,000; and Institutional accounts to a have minimum account value of $5 million. Confluence allows firm personnel and their family members to maintain accounts that Confluence manages. Some Confluence employees also invest in the open-end mutual fund and closed-end fund that Confluence sub-advises. Confluence employees may suggest recommend investment companies that Confluence sub-advises to certain clients. This presents a conflict of interest in that it could create an incentive for Confluence to favor these funds over other investment companies. Confluence maintains investment and trade allocation policies designed to manage such conflicts of interest. Item 8—Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Confluence employs fundamental and cyclical security analysis methods, which vary by the type of portfolio strategy provided. Confluence’s Equity strategies, which are comprised of common equity securities of companies, utilize a bottom-up, fundamental approach. Confluence’s Asset Allocation and Fixed Income strategies, and the fixed income portion of our Balanced accounts strategies, are implemented using exchange-traded funds (“ETFs”), and utilize a top-down, cyclical approach. An ETF is an individual security that trades on an exchange and represents a basket of securities or other assets that are typically designed to track the performance of targeted indices, sectors or asset classes. The firm’s Global Hard Assets strategy, which is primarily comprised of common equity securities and a portion of ETFs, utilizes a combination of the above two approaches. Confluence also manages sector-specific strategies (e.g., Business Development Companies, Real Estate Investment Trusts and Utilities) that utilize both top-down and bottom-bottom- up approaches. For the Increasing Dividend Equity Account (“IDEA”) Plus strategy, which is an equity strategy combined with a covered call option strategy on the S&P 500 Index, the firm analyzes option securities for their strike price, premium, volatility and term. Approximately 75% of the portfolio is the IDEA portfolio of common equity securities, in which the stock selection utilizes qualitative analyses in an attempt to identify high-quality companies with long track records of distributing earnings to shareholders through dividends. The remaining 25% consists of an ETF position in the S&P 500 Index with a corresponding covered call position, although this allocation will fluctuate due can range at times from 15% to account size and/or the price 40% of the Indexportfolio. A substantial portion of investment research is generated in-house. Confluence also utilizes external research sources, such as Bloomberg, Xxxxx Analytics, Xxx Xxxxx, FactSet, Refinitiv Advantage Data and various governmental banking and agency data. Confluence will also utilize analytics from other private market research institutions.. INVESTMENT STRATEGIES – METHODOLOGY