Regulatory Disclosures

Under the Investment Advisers Act of 1940 and the U.S. Securities and Exchange Commission (“SEC”) we are required as a registered investment adviser to deliver certain disclosure documents to each of our clients. These documents contain information about our firm and the steps we take to ensure that we serve our client’s best interests.

• Firm Brochure (ADV Part 2A)

• Form CRS

• Privacy Policy

• Proxy Voting Policy

• Jonathan Spencer - ADV Part 2B

• David Ventura - ADV Part 2B

• John Laughlin - ADV Part 2B

• Michael Liccar - ADV Part 2B