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ALLARIA ASSET MANAGEMENT, LLC COMPENSATION AND CONFLICTS DISCLOSURE

This disclosure provides information about the business practices, compensation and conflicts of interest related to the collective brokerage and advisory business of Allaria Securities, LLC (“ASE”) and Allaria Asset Management, LLC (“AAM”) (referred to collectively as “we,” “us,” or “AllariaUS ”). Additional information about AllariaUS and its financial professionals is available on FINRA’s website at http://brokercheck.finra.org. or via the SEC’s website at www.sec.gov.

TABLE OF CONTENTS

1. ITEM 1 INTRODUCTION
2. ITEM 2 COMMISSIONS, FEES AND OTHER TYPES OF SALES COMPENSATION
3. ITEM 3 THIRD PARTY COMPENSATION
4. ITEM 4 PRODUCT COSTS AND RELATED CONFLICTS
5. ITEM 5 CUSTOMER REFERRALS, OTHER COMPENSATION, AND OTHER CONFLICTS
6. ITEM 6 FINANCIAL PROFESSIONAL COMPENSATION, FEES AND RELATED CONFLICTS
7. ITEM 7 OTHER FINANCIAL INDUSTRY AFFILIATIONS

ITEM 1 INTRODUCTION

Allaria Securities, LLC is a broker-dealer registered with the Securities and Exchange Commission (SEC) and member of the Financial Industry Regulatory Authority (FINRA). As a broker-dealer, ALLARIA transacts business in various types of securities, including mutual funds, exchange-traded funds (ETFs), stocks, bonds, commodities, options, private and public partnerships, variable annuities, real estate investment trusts (REITs) and other investment products, while offering such services to clients located domestically, as well as outside of the U.S.

Allaria Asset Management’ is a registered investment adviser with the SEC and the State of Florida that provides advisory services to individuals, including high net worth individuals, , trusts, corporations or other business entities domiciled or residing in the United States, Latin America and other countries abroad. Clients may elect Allaria Asset Management to manage a portion or all of their assets on a discretionary or non-discretionary basis.

AllariaUS maintains a network of individuals, referred to as “financial professionals”, who offer brokerage services, investment advisory services, or both, depending on their licenses. Some of AllariaUS’s financial professionals are investment adviser representatives (IARs) of Allaria Asset Management.

AllariaUS sometimes refers to these specific financial professionals as “financial advisors” or “advisors.” AllariaUS’s financial professionals are primarily independent contractors though there are some who are employees.

Although most financial professionals offer both brokerage and investment advisory services, some only offer brokerage services and others only offer investment advisory services. When you are discussing services with a financial professional, you should ask what capacity the financial professional is acting or will be acting – as a broker-dealer registered representative and/or an IAR – when providing services to you. This disclosure discusses important information regarding financial professionals who act as registered representatives of AllariaUS’s brokerdealer. For more information about AllariaUS and the services financial professionals provide when they act as IARs, please contact AllariaUS at +1-(786) 686-5400

AAM Form ADV disclosure brochures available at www.adviserinfo.sec.gov or contact your investment adviser for a copy of its Form ADV. For additional information on which type of investment account is right for you, please see AllariaUS’s Form CRS (Customer Relationship Summary) that will soon be on www.allariasecurities.com/disclosures.html.

Like all financial services providers, AllariaUS, and its financial professionals have conflicts of interest. AllariaUS and its financial professionals may be compensated directly by customers and indirectly from the investments made by customers. When customers pay us, we typically get paid an upfront commission or sales load at the time of the transaction and in some cases a deferred sales charge. If we are paid an upfront commission, it means that we are paid more the more transactions a customer makes. When we are paid indirectly from the investments made by customers, we receive ongoing compensation, typically called a “trail” payment, for as long as a customer holds an investment. In addition, we may receive compensation from the sponsors of some of the investment products that customers purchase through us. The amount we may receive varies depending on the particular type of investment a customer makes. The compensation described in this disclosure represents the maximum gain or profit we may receive on an investment, before subtraction of our expenses.

Please also note that not all of the conflicts described in this disclosure apply to a particular financial professional, his /her services, or all the products we sell. The types and amounts of compensation we receive change over time. You should ask your financial professional if you have any questions about compensation, costs, fees, or conflicts of interest.

ITEM 2 COMMISSIONS, FEES, AND OTHER TYPES OF SALES COMPENSATION
Commissions and Sales Charges

ASE receives upfront commissions when it executes transactions that result in the purchase or sale of a security. A commission, which also may be called a sales load, sales charge or placement fee, is typically paid at the time of the sale and can reduce the amount available to invest or can be charged directly against an investment. Commissions are often based on the amount of assets invested. ASE receives the sales charge or commission and may share it with your financial professional. In some cases, a portion of the sales charge or commission is retained by the investment’s sponsor. Commissions vary from product to product, which creates an incentive to sell a higher commission security rather than a lower commission security. The maximum and typical commissions for common investment products are listed below. For more information about other commissions that apply to a particular transaction, please refer to the applicable investment’s prospectus or other offering document.

• Equities and Other Exchange TradedSecurities. The maximum commission charged by ASE in an agency capacity on an exchange-traded security transaction, such as an equity, option, ETF, exchange traded note (ETN) or closed-end fund (CEF), is a fixed charge that may vary between $16 and $35 plus 1.0% of the transaction amount, and in the case of option contracts a $1 per contract may be added. There may be some fee arrangements which contemplate a minimum charge between $55 and $100. . In addition, the financial professional can decide to discount the commission amount to a minimum of $35 per transaction.
• Off-shore Mutual Funds. The maximum commission or sales charge permitted under applicable rules is 8.5%, although the maximum is typically 5.75%.
• Alternative Investments. For alternative investment products, such as hedge funds, private equity funds, non-traded business development companies (BDCs), real estate private placements, or real estate investment trusts (REITs), the upfront sales load is as high as 5.5%

Markups and Markdowns – Principal or Dealer Transactions

When ASE buys from or sells a security to you in a principal capacity, ASE buys or sells the security directly from you, rather than acting as your agent to buy or sell the security from a third party. These transactions are also known as “dealer transactions.” In these circumstances, if we sell a security at a price higher than what we paid for it, we will earn a markup. Conversely, if we buy a security from you at a price lower than what we sell it for, we will earn a markdown. Transactions in bonds and other fixed-income securities such as structured products often occur as dealer transactions.

The maximum markup/markdown on a transaction with a customer that we receive when acting in a principal capacity typically does not exceed 2.5% of the value of the security. On rare occasions, a markup/markdown may exceed 2.5% on a deeply discounted security. In many cases, the actual markup/markdown percentage is lower based on factors such as quantity, price, type of security, rating, maturity, etc.

Direct Fees and Charges

If you hold an account at ASE, ASE charges miscellaneous fees directly to your account such as fees for transaction processing, account transfers, and account maintenance. For direct fees that apply per transaction, ASE receives more fees the more transactions that result from a financial professional’s recommendation. These direct fees and charges are set out in the Miscellaneous Account and Service Fee Schedule at www.allariasecurities.com/disclosures.html, are not shared with financial professionals, and are not charged by ASE if you hold an account directly with a product sponsor rather than with ASE

ITEM 3 THIRD PARTY COMPENSATION

ASE and financial professionals may receive compensation from investment product sponsors and other third parties in connection with investments that ASE customers make in securities such as mutual funds, annuities, and alternative investments. Some types of third-party compensation are received by ASE and shared with financial professionals, and other types are retained only by ASE. For more information about the third party compensation ASE receives, the investment product sponsors and other third parties that pay ASE the compensation, and related conflicts of interest, please see the Third Party Compensation and Related Conflicts of Interest on www.allariasecurities.com/disclosures.html.

ThirdPartyCompensationSharedbyALLARIAandFinancialProfessionals Trail Compensation

ASE and its financial professionals may receive ongoing compensation from certain investment products such as mutual funds, annuities and alternative investments. This compensation (commonly known as trails or Rule 12b-1 fees) is typically paid from the assets of the investment product under a distribution or servicing arrangement with the investment sponsor and is calculated as an annual percentage of assets invested by ASE customers. The more assets you invest in the product, the more we will be paid in these fees. Therefore, we have an incentive to encourage you to increase the size of your investment. The amount of trails received varies from product to product. This creates an incentive to recommend a product that pays a higher trail rather than a lower trail. We also have an incentive to recommend a product that pays trails (regardless of amount) rather than products that do not pay trails. For more information about trail compensation received with respect to a particular investment, please refer to the prospectus or offering document for the investment.

• Off-Shore MutualFunds. The ongoing payment depends on the class of shares but is typically between 0.25% and 1% of assets annually.
• Alternative Investments. For alternative investment products, such as private funds, trail payments may be as high as 1.25% on an annual basis. Trail payments for managed futures funds can be as high as 2% annually.

Concessions and Mutual Fund Finder’s Fee

In certain cases, ASE and financial professionals may receive compensation from a mutual fund sponsor in connection with transactions for which sales charges are waived or under other circumstances and as described in a fund’s offering documents. This compensation is generally referred to as a finder’s fee or concession and typically ranges between 0.25% and 1% of the transaction amount. ASE also receives concessions from investment sponsors for other types of investments. These concessions vary from product to product, and are generally shared between ASE and the financial professional. Concessions can be as high as 0.25% of the transaction amount for new issues of certificates of deposit, municipal bonds and other shortterm dated bonds, up to 3% of the transaction amount for structured products, and up to 4% of the transaction amount for CEFs.

Non-Cash Compensation

ASE, ASE employees, and financial professionals may receive non-cash compensation from investment sponsors that is not in connection with any particular customer or investment. Compensation may include such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings, customer workshops or events, or marketing or advertising initiatives, including services for identifying prospective customers. Investment sponsors also pay, or reimburse ASE and/or its financial professionals, for the costs associated with education or training events that may be attended by ASE employees and financial professionals and for ASE sponsored conferences and events.

Third Party Compensation Retained by ALLARIA Cash Sweep

For accounts held at ASE, uninvested cash balances are automatically invested in a money market sweep fund. ASE receives compensation for marketing support from the sponsors to these funds, ranging between 0.16% and 0.35% of the assets invested in the money market funds. These payments are in addition to other fees (e.g., recordkeeping and 12b-1 fees) received by ASE.

Depending on interest rates and other market factors, the yields on money market sweep fund have been, and may continue in the future to be, lower than the aggregate fees and expenses received by ASE for a customer’s participation in the cash sweep programs. This may result in a customer experiencing a negative overall investment return with respect to cash balances in the cash sweep programs. Customers should compare the terms, interest rates, required minimum amounts and other features of the sweep program with other types of accounts and investments for cash.

Non-Sweep Money Market Mutual Funds

Customers are able to invest cash balances in a limited number of money market mutual funds other than as part of a sweep arrangement (Non- Sweep Money Market Funds). Depending on interest rates and other market factors, investment returns of money market mutual funds have been, and may continue in the future to be, lower than the aggregate fees and expenses charged by ASE in connection with the transaction. This may result in a customer experiencing a negative overall investment return with respect to cash reserves invested in the Non-Sweep Money Market Funds. Customers should understand that the share class offered for a particular Non-Sweep Money Market Fund charges higher fees and expenses than other share classes that are offered by the same Non-Sweep Money Market Fund but are not available on ASE’s platform. ASE receives compensation for the ASE customer assets invested in the Non-Sweep Money Market Funds for distribution, recordkeeping, shareholder servicing and administrative services it provides for the funds and in connection with marketing support services ASE provides to the fund sponsors as described in this disclosure.

Unlike other types of mutual funds available on ASE’s platform, ASE makes available Non-Sweep Money Market Funds from only a limited number of mutual fund sponsors. By making available a limited number of Non-Sweep Money Market Funds, ASE is able to negotiate greater compensation from the fund companies for services it provides to the funds. Because of the limited number of Non-Sweep Money Market Funds available on the platform and the fees paid by those funds, other money market mutual funds not available through ASE’s brokerage platform are likely to have higher returns than the Non-Sweep Money Market Funds.

ITEM 4 PRODUCT COSTS AND RELATED CONFLICTS

Financial professionals may provide recommendations with respect to a broad range of investment products, including stocks bonds, ETFs, mutual funds, annuities and alternative investments. Each type of investment product carries unique risks, and many investment products charge fees and costs that are separate from and in addition to the commissions and fees that ASE and financial professionals receive. You can learn more about these risks and the fees and costs charged by an investment product by reviewing the investment product’s prospectus, offering memorandum, or other disclosure documents.

Set out below is the typical range of expenses of the various investment products we sell. In most cases, these expenses are in addition to the commissions and fees that ASE receives for its brokerage services.

• ETFs. The expense ratios range from 0.05% to 1.0%, with an average expense ratio of around 0.44%.
• Mutual Funds. Expense ratios can vary based on the type of mutual fund purchased. The average expense ratio for actively managed funds is 0.5% to 1.0%, for passive index mutual funds the average is 0.2%.
• Alternative Investments. The typical range of annual expenses, excluding any commissions or dealer manager fees, is 0.80% to 6.00% which may include management fees, acquisition fees, disposition fees, performance participation fees, organization and offering fees, acquired fund fees and expenses, or interest payments on borrowed funds.

Share Class and Fund Selection

ASE offers various share classes of mutual funds. As an example, certain mutual fund share classes, often referred to as Class A shares, charge an upfront sales charge and an ongoing trail. For other mutual fund share classes, often titled Class C shares, there is no upfront sale charge paid, however, there is an ongoing trail payment and a contingent deferred sales charge to the investor if there is a redemption within a certain period of time after purchase. Depending on the length of the holding period for the mutual fund, and other factors, one share class may be less expensive to the investor than another, and ASE and the financial professional may earn more or less in compensation for one share class than another. Because of their characteristics and sales load structure, mutual funds generally are longer term investments. Frequent purchases and sales of mutual funds can result in significant sales charges unless the transactions are limited to exchanges among mutual funds offered by a sponsor that permits exchanges without additional sales charges. ASE maintains policies and procedures that are designed to detect and prevent excessive mutual fund switching, but you should monitor your account and discuss with your financial professional any frequent mutual fund purchases and sales.

Some share classes or funds we offer do not charge or pay to us an upfront sales charge, and pay us ongoing trails of 0.25% or less annually (“no- load funds”). ASE makes no-load funds available only to certain customers or through certain of our programs. We may be compensated in other ways by sponsors of no-load funds, such as through revenue sharing payments. Because of the limited compensation from no-load funds, we have an incentive to limit the availability of no-load funds we offer and to recommend you invest in funds that impose sales charges and trails.

ASE also offers various mutual funds and ETFs, some of which have similar or identical investment strategies but differing fee structures. For example, a mutual fund that is designed to track an index of securities, such as the S&P 500 Index, may have higher or different types of fees than an ETF that is designed to track the same index. Whether a fund or ETF is more expensive than another fund or ETF with a similar or identical investment strategy may depend on factors such as length of holding, size of the initial investment and other factors. ASE and a financial professional may earn more compensation for one fund or ETF than another, giving ASE and the financial professional an incentive to recommend the product that pays more compensation to us.

ITEM 5 CUSTOMER REFERRALS, OTHER COMPENSATION, AND OTHER CONFLICTS
Payment for Referrals

ASE may offer programs where ASE pays professionals, such as attorneys or accountants, for referrals. In one such program, ASE would pay such professionals for referrals exclusively to its advisory business, and customers must acknowledge the referral payment to the professional. In another program, the professionals would register as representatives of ASE and share in brokerage commissions and advisory fees in connection with the referral.

ALLARIA and financial professionals may enter into lead generation, marketing and/or referral arrangements with third parties and other financial intermediaries, including for the purpose of introducing new customers. The fees paid for these services can be structured in various ways, including an ongoing flat fee.

Margin

ASE offers customers the ability to purchase securities on credit, also known as margin purchases. When a customer purchases securities on margin, ASE extends a line of credit to the customer and charges interest on the margin balance. ALLARIA has a financial incentive to encourage margin borrowing because ALLARIA earns compensation in the form of interest, transaction charges and other fees on investments made with borrowed amounts. That financial incentive creates a conflict of interest insofar as ALLARIA and financial professionals benefit from your decision to borrow and incur the various fees and interest described above. If contemplating use of margin, please consult the ALLARIA Margin Agreement and related disclosures for additional details.

Error Correction

If a customer holds an account at ASE and a trade error caused by ASE occurs in the account, ASE will cancel the trade and remove the resulting monetary loss to a customer from the account. If a trade correction is required as a result of a customer (e.g., if a customer does not make full payment for purchases or fails to deliver negotiable securities for liquidations before trade settlement), ASE will cancel the trade and any resulting monetary loss will be borne by the customer. In the case of a trade that requires a correction and that resulted in a monetary gain to the customer, such gain may be removed from the account and may result in a financial benefit to ASE.

Rollovers

If a customer decides to roll assets out of a retirement plan, such as a 401(k) plan, and into an individual retirement account (IRA), we have a financial incentive to recommend that a customer invests those assets with ALLARIA, because we will be paid on those assets, for example, through commissions, fees and/or third party payments. A customer should be aware that such fees and commissions likely will be higher than those the customer pays through the plan, and there can be custodial and other maintenance fees. As securities held in a retirement plan are generally not transferred to an IRA, commissions and sales charges may be charged when liquidating such securities prior to the transfer, in addition to commissions and sales charges previously paid on transactions in the plan. For more information about rollovers, see allariasecurities.com/disclosures.html under IRA Rollover Information.

Limitations on Investment Recommendations

ASE and financial professionals offer and recommend investment products only from investment sponsors with which ASE has entered into selling and distribution agreements. Other firms may offer products and services not available through ASE, or the same or similar investment products and services at lower cost. In addition, ASE may only offer certain products in a brokerage account, even though there is a version of the product that may be offered at a lower cost through an advisory account, and vice versa.

The scope of products and services offered by certain financial professionals may also be more limited than what is available through other financial professionals. A financial professional’s ability to offer individual products and services depends on his/her licensing, training or branch office policy restrictions. For example, a financial professional maintaining a Series 6, Series 63 and Life Insurance Agent license is limited to providing investment company securities, such as mutual funds and UITs and variable annuity contracts. A financial professional maintaining a Series 7, Series 63 and Life Insurance Agent license is able to provide solutions including all securities available for sale by a Series 6 representative as well as individual stocks, bonds, and alternative investments, among others. As another example, a financial professional may only be licensed to provide brokerage services, and not advisory services, or vice versa. To provide investment advisory services, a financial professional is often required to be registered as an IAR with the state in which he/she has a place of business. You should ask your financial professional about the securities or services he/she is licensed or qualified to sell, and his/her ability to service investments that you transfer to ASE from another firm. You should also review the licenses held by your financial professional by visiting the FINRA BrokerCheck system at http://brokercheck.finra.org.

Investment Advisory Account – Directed Brokerage

When a client retains AAM to manage his/her account on a discretionary or non-discretionary basis, the client grants AAM the authority to select the broker-dealer(s) that will be used to place and execute the transactions in the advisory accounts. It is the policy and practice of AAM to strive for the best price and qualitative execution that are competitive in relation to the value of the transaction (best execution). In selecting a broker-dealer or other intermediary, AAM will consider such factors that in good faith and judgment it deems reasonable under the circumstances.

Use of ASE (Affiliate FINRA Member Broker-Dealer). AAM routinely directs brokerage to ASE Brokerage. Not all advisers require their clients to direct brokerage to a particular broker-dealer. By directing achieve most favorable execution and this practice can cost clients more money.

ASE and AAM accounts a flat “execution commissions”/brokerage commission related to cost of executing advisory transactions on behalf of AAM customers. ASE does not share the aforementioned flat execution commissions with IARs. Such commissions and fees are maintained solely by ASE Brokerage, which also indirectly benefits the owners of AAM since both entities are under common ownership. ASE Brokerage’s execution fees/commissions are in addition to any clearing related fees assessed by the clearing firm such as ticket charges for transactions and separate from advisory fees charged by AAM. ASE maintains negotiated fee schedule with Pershing, LLC (“Pershing”), which in certain instances includes a markup on related clearing firm fees. Based upon this structure, ASE and (in turn its common owners with AAM) will receive additional economic benefit (revenues) from the negotiated fee schedules or additional services based on the transaction volume attributable to the advisory accounts.

ASE is an introducing broker-dealer that clears through Pershing. AAM evaluates certain factors in connection with its selection of ASE as its primary designated broker-dealer for advisory customer accounts. Listed below are the primary considerations AAM weighs in its evaluation of its arrangement with ASE Brokerage:

• ASE has expertise in the markets and types of securities desired;
• ASE has the ability to execute directly in the desired markets;
• Pershing, LLC is a qualified custodian;
• The knowledge and close relationship between the ASE traders and the advisory personnel which helps to facilitate the communication process and allows for quicker handling of execution instructions;
• Ability to service foreign clients and associated costs, including commission rates, ticket charges and other service charges in comparison to other clearing firms providing similar services;
• Efficiency and accuracy of execution, clearance and settlement provided by Pershing, LLC;
• Responsiveness of Pershing’s customer service team;
• ASE Brokerage’s and Pershing’s commitment to technology and the security of confidential information;
• Neither ASE nor Pershing has provided any indication or representation that they would be unable to fulfill its financial responsibilities or is at risk for financial insolvency;
• The overall reputation and professional integrity of Pershing.

Due to the common ownership, dual association of representatives and additional compensation your advisory representative and AAM maintains a conflict/incentive to recommend and execution transactions via ASE Brokerage

ITEM 6 FINANCIAL PROFESSIONAL COMPENSATION, FEES AND RELATED CONFLICTS

ASE generally compensates financial professionals pursuant to an independent contractor agreement, and not as employees. However, some financial professionals are employees of ASE. Described below are the compensation and other benefits that independent contractor financial professionals receive from ASE.

Cash Compensation

ASE typically pays a financial professional a percentage of the revenue he/she generates from sales of products and services. The percentage received can vary (typically between 60% to 90%) depending on his or her agreements with ASE and the investment product or service recommended, and can be more or less than what he/she would receive at another brokerage firm. The payments might include a bonus that is based on the amount of assets serviced or revenue generated by the financial professional. When compensation is based on the level of production or assets, the financial professional has a financial incentive to meet those production or asset levels.

Other Benefits

Financial professionals are eligible to receive other benefits based on the revenue he/she generates from sales of products and services. These benefits present a conflict of interest because the financial professional has an incentive to remain a registered representative of ASE in order to maintain these benefits. These benefits include eligibility for practice management support and enhanced service support levels that confer a variety of benefits, conferences (e.g., for education, networking, training, and personal and professional development), and other non-cash compensation. If ASE makes a loan to a new or existing financial professional, there is also a conflict of interest because ASE’s interest in collecting on the loan affects its ability to objectively supervise the financial professional.

Fees Charged to Financial Professionals

ASE charges financial professionals’ various fees under its independent contractor agreement for, among other things, trade execution, administrative services, insurance, certain outside business activity related supervision, technology and licensing. Depending on the situation, these fees make it more or less profitable for the financial professional to offer and recommend certain services or products over others.

Financial Professional’s Outside Business Activities

Financial professionals are permitted to engage in certain ASE-approved business activities other than the provision of brokerage and advisory services through ASE, and in certain cases, a financial professional receives more compensation, benefits and non-cash compensation through the outside business than through ASE. Some financial professionals are accountants, real estate agents, insurance agents, tax preparers, or lawyers, and some financial professionals refer customers to other service providers and receive referral fees. As an example, a financial professional could provide advisory or financial planning services through an unaffiliated investment advisory firm, sell insurance through a separate business, or provide third party administration to retirement plans through a separate firm. If a financial professional provides investment services to a retirement plan as a representative of ASE and also provides administration services to the plan through a separate firm, this typically means the financial professional is compensated from the plan for the two services. If you engage with a financial professional for services separate from ASE, you may wish to discuss with him/her any questions you have about the compensation he/she receives from the engagement. Additional information about your financial professionals outside business activities is available on FINRA’s website at http://brokercheck.finra.org

Compensation for Other Services

ASE and financial professionals can offer various types of advisory and brokerage programs, platforms and services, and earn differing types and amounts of compensation depending on the type of service, program or platform in which you participate. This variation in compensation can incentivize a financial professional to recommend services, programs or platforms that generate more compensation for ASE and the financial professional than others. For example, if you expect to trade securities frequently in your account, a brokerage account in which you pay a commission for each transaction may generate more compensation for your financial professional than an advisory account that generates compensation in the form of investment advisory fees.

ITEM 7 OTHER FINANCIAL INDUSTRY AFFILIATIONS

ALLARIA is not affiliated with other financial services companies.

Please consult the Disclosures page on ALLARIA’s website for the current information about ALLARIA’s brokerage and advisory compensation and related conflicts of interest. ALLARIA posts changes to this disclosure on its website allariasecurities.com/disclosures.html on a periodic basis. ALLARIA may not notify you when these changes are made, so you should consult the website to learn about any changes that have been implemented accordingly. If you are unable to access the website or require paper copies of any documents referenced in his information, please contact a financial professional.

PRIVACY POLICY AND PRACTICES

Allaria Asset Management, LLC Collectively Allaria recognize and respect the privacy expectations of our clients. We do not sell information about current or former customers or their accounts to third parties. We provide this notice to you so that you will know what kinds of information we collect about clients and the circumstances in which that information may be disclosed.

COLLECTION OF CUSTOMER INFORMATION

We collect nonpublic personal information about our clients from the following sources:

• Account Applications, client profiles and other forms, which may include a client’s name, address, social security number, and information about a client’s investment goals and risk tolerance
• Account History, for example, copies of confirmations or statements which may include information about investment transactions or the balances in a client’s account
• Correspondence, written, telephonic or electronic between a client and Allaria

DISCLOSURE OF CUSTOMER INFORMATION

We will not disclose any of the client information we collect to third parties who are not affiliated with the Allaria other than:

• to effect or administer transactions at your request
• as permitted or required by law or regulation – for example, to service provider, in connection with an audit or examination, or to respond to a subpoena or similar legal process

SECURITY OF CUSTOMER INFORMATION

We have physical, electronic and procedural safeguards to protect nonpublic personal information of our clients. We will adhere to the policies and practices described in this notice regardless of whether you are a current or former client. Allaria may restrict access to client nonpublic personal information by, among other things, password-protecting electronic information, having such information in a designated location that is not accessible to all employees, or otherwise segregating such information.

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies individuals and/or institutions seeking to open an account.

What this means for you:

Documents and/or other information may be requested to verify your identity and/or the existences of the entity establishing the account such as a business address, tax identification numbers and any other documents that will prove the existence of the entity for which an account is being established.

Allaria Securities, LLC, (“Allaria”) maintains a Business Continuity Plan (BCP) in the event of a building, city-wide, or regional incident. It is the policy of Allaria to be prepared to respond to a significant business disruption in a manner that:

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies individuals and/or institutions seeking to open an account.

• Safeguards employees’ lives and Firm property
• Allows the Firm to make an expedient financial and operational assessment
• Recovers adequate functionality as soon as possible
• Protects all of the Firm’s books and records
• Allows customers to transact business and access to their assets

Our clearing firm, Pershing LLC maintains the Firm’s customers’ accounts, can grant customer access to them, and deliver funds and securities. In the event that the Firm determines it is unable to continue its business, it will assure customers prompt access to their funds and securities through Pershing LLC.

If Pershing were to experience a significant business disruption, their business continuity plan outlines their actions, including relocating technology and operational personnel to preassigned alternate regional facilities. Technology data processing can also be switched to an alternate regional data center.* All of Pershing’s operational facilities are equipped for the resumption of business and have a recovery time objective of four (4) hours. This recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond our control.

CLIENT INSTRUCTIONS

If Allaria were to experience a significant business disruption, Pershing may be contacted directly to process limited trade-related transactions, cash disbursements, and security transfers. Instructions to Pershing must be in writing and transmitted via facsimile or postal service as follows:

Pershing, LLC
P.O. Box 2065
Jersey City, NJ 07303-2065
Fax: (201) 413-5368

For additional information about how to request funds and securities when Allaria cannot be contacted due to a significant business disruption, please refer to the information below or call (201) 413-3635 for recorded instructions. If you cannot access the instructions from the previously noted telephone number, Pershing may be contacted at (213) 624-6100 extension 500 as an alternative telephone number for recorded instructions.

The specific transactions Pershing will perform for clients of Allaria and the required accompanying information, are as follows:

• Trades

Pershing will process the following closing security transactions:

• Sale of security position held long in the client’s account
• Buy of security to close-out short security position

Pershing will process closing security transactions upon receipt of written instructions that must include the following information:

• Client brokerage account number
• Client name (as registered on the brokerage account)
• Security description, including symbol or CUSIP® number
• Number of shares (NOTE: All orders will be handled as market orders)
• Cash Disbursements

Pershing will process cash disbursements upon receipt of signed written instructions that must include the following information:

• Client brokerage account number
• Client name (as registered on the brokerage account)
• Exact amount to be disbursed
• Indicate method of disbursement (as follows) and provide the information indicated:
• Check (payable to account name only)
• Indicate name and address of record check is to be mailed to
• Federal funds
• Indicate receiving bank name, ABA number, and receiving bank account number

NOTE: The receiving bank account name and brokerage account name must be identical unless we have a letter of authorization on file indicating alternate instructions.

Securities Transfers

Pershing will process security transfer requests upon written instructions that must include the following information:

• Client brokerage account number
• Client name (as registered on the brokerage account)
• Description of security(ies) to be transferred, including symbol(s) or CUSIP number(s)
• Quantity to be transferred
• Receiving account information for securities, as follows:
• Transfer to another brokerage account at Pershing
• Provide receiving account number at Pershing (name and address on both accounts must be the same)
• Transfer to another financial organization
• Name of receiving financial organization
• DTC number (if the receiving financial organization is a registered broker-dealer)
• Account number at the receiving financial institution

* Pershing’s contingency plans to address unexpected, extended service disruptions include the possibility of such a disruption at Pershing but not at Allaria. In such a situation, Allaria would be able to provide securities trading services to its clients over a web-based connection in conjunction with Pershing’s contingency plans. Allaria has procedures and designated personnel authorized to implement the trading system and thereby minimize any such disruption.