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Important Information about Investment Managers Trading Away in J.P. Morgan Securities LLC ("JPMS") Wrap Fee Investment Advisory Programs

Through J.P. Morgan Securities (a brand name for a wealth management business of JPMS), JPMS offers the following wrap-fee investment advisory programs that include the discretionary portfolio management of client assets by third-party Investment Managers:  the Strategic Investment Services (“STRATIS”) Program; Investment Counseling Service (“ICS”) Program; Unified Managed Account (“UMA”) Program; Customized Bond Solutions (“C-BoS”) Program; and Systematic Managed Accounts (“SMA”) Program (collectively, “Wrap Fee Programs”). This document provides information to clients, who are participating, or are considering participating, in a Wrap Fee Program, about Investment Managers’ placement of client trade orders for execution by broker-dealers other than JPMS. This practice is frequently referred to as “trading away.”

The extent to which an Investment Manager chooses to trade away from JPMS can affect your total cost of investing. When an Investment Manager places trades with JPMS for execution in a Wrap Fee Program, your account does not incur any additional costs because trade execution by JPMS is covered by the wrap fee you pay to JPMS. However, when an Investment Manager chooses to trade away from JPMS, execution by a broker-dealer other than JPMS is not covered by the wrap fee and your account therefore may incur a commission or other additional cost.

Best Execution Obligations
In the Wrap Fee Programs, third-party Investment Managers have investment discretion over your account (or, in the case of the UMA Program, over those “sleeves” of the account consisting of separately managed account investment strategies). Typically, Investment Managers in the Wrap Fee Programs are directed by you to place trade orders with JPMS for execution, subject to their duty of “best execution” and JPMS’s capacity and willingness to execute the trade (as in the case of fixed income trades, which as explained below, JPMS typically does not accept for execution).  Investment Managers, as investment advisers, have an obligation to seek “best execution” of client trade orders. “Best execution” means that Investment Managers have the responsibility to execute trades through those broker-dealers that they consider able to provide the best qualitative execution under the circumstances. An Investment Manager may determine that JPMS or another broker-dealer’s execution capabilities provide the most favorable option under the circumstances.

An Investment Manager commonly reviews several factors indicative of a broker-dealer’s trade execution quality in order to comply with its best execution obligation. An Investment Manager can examine the full range and quality of a broker-dealer’s services, including but not limited to: the nature of the security, the size and type of transaction, the nature and character of relevant markets, the executing broker’s execution, clearance and settlement capabilities and reputation, soft dollar arrangements, and the speed, knowledge, efficiency, consistency and anonymity provided by the executing broker. Additional trading costs associated with trading away, as described below in “Trading Away and Associated Costs,” may be one of several factors an Investment Manager evaluates when complying with its best execution obligation. However, the best execution obligation does not require an Investment Manager to solicit competitive bids for each transaction or to seek the lowest available cost of trade orders, as long as the manager reasonably believes that the broker-dealer selected can be reasonably expected to provide clients with the best qualitative execution under the circumstances.  There is no single formula or process required for an Investment Manager to meet its best execution obligation; the factors analyzed and the weight given to each factor can vary by Investment Manager.

Trade Aggregation and Trade Rotation Practices
Investment Managers may participate in other wrap fee programs besides those offered by J.P. Morgan Securities, and may also manage institutional or other accounts that are not part of any wrap fee program. In order to avoid buying or selling the same security for all client accounts through multiple broker-dealers, an Investment Manager may decide to aggregate all such client transactions into a block trade that is executed through one broker-dealer. This practice, known as “trade aggregation,” may allow an Investment Manager to obtain more favorable execution, including more favorable pricing, than would otherwise be available if orders were not aggregated. Trade aggregation may also aid an Investment Manager in avoiding an adverse effect on the price of a security that could result from simultaneously placing a number of separate successive or competing client orders. Trade aggregation by an Investment Manager generally results in trading away from JPMS.

Alternatively, an Investment Manager may employ a trade rotation process where one group of clients has a transaction effected before or after another group of an Investment Manager’s clients.  A trade rotation process minimizes the impact of an Investment Manager’s trading on the securities or markets in which an Investment Manager trades. As a client, you should be aware that an Investment Manager’s trade rotation practices may at times result in a transaction being effected for your account near or at the end of the manager’s rotation. In this event, your trade orders will bear the market price impact, if any, of those trades executed earlier in the manager’s rotation, and, as a result, you may receive a less favorable net price for the trade. However, Investment Managers’ trade rotation procedures are generally designed to treat clients equitably and fairly over time.

Trading Away and Associated Costs
Because you will not pay additional trading costs when JPMS is the broker-dealer that executes a trade order in your Wrap Fee Program account, Investment Managers may determine that JPMS’s execution capabilities as broker-dealer provide the most favorable option for placing trade orders in your account. However, as noted above, an Investment Manager may choose to trade away if such Investment Manager reasonably believes that another broker-dealer will provide a more favorable execution under the circumstances, notwithstanding any additional costs that you may incur.

When an Investment Manager trades away, the trades are executed at a broker-dealer other than JPMS and are cleared and settled at JPMS. If an Investment Manager executes trade orders with a broker-dealer other than JPMS, you may incur trading costs in addition to the fees charged by JPMS for your participation in the Wrap Fee Program.  The broker-dealer executing the trade-away transaction may charge fees that may include commissions, markups, markdowns or “spreads” paid to market makers, which will be borne by you. Additionally, if a foreign currency transaction is required, a foreign broker-dealer may receive compensation in the form of a dealer spread, markup or markdown. There may be other exchange or similar fees charged by third parties, including but not limited to those relating to foreign currency conversion, creation of American Depositary Receipts (“ADRs”), and foreign tax charges.  Ordinarily, you will not be able to tell by looking at your trade confirmation or account statement whether you incurred additional costs (or the amount of any such costs) in connection with trading away by an Investment Manager, because any such costs are typically not identified separately on such documents but instead are generally incorporated into the net price of the trade.

Depending on the types of securities traded in a portfolio in the Wrap Fee Programs, certain Investment Managers may place all or substantially all of certain types of trades with another broker-dealer for execution. In the context of wrap fee programs generally, for example, it is not uncommon for investment managers to trade away in fixed income, foreign security, and small-cap equity strategies. In a wrap fee program, therefore, such types of securities could be more costly to you than other types of strategies in which investment managers may more commonly place trades with the sponsoring broker-dealer for execution.

You should note in particular that JPMS does not accept fixed income trades for execution in the Wrap Fee Programs. Because of this, when an Investment Manager that participates in a Wrap Fee Program wants to place a trade in a fixed income security, like a bond, note, or debenture, such Investment Manager will have to trade away, even if it would have preferred to use JPMS to execute the trade.  Accordingly, you should expect that all fixed income trades in your account(s) in the Wrap Fee Programs will be executed by broker-dealers other than JPMS and that you may incur transactional costs in connection with the trades that are not covered by the wrap fee you pay to JPMS.

Fixed income securities are primarily traded in dealer markets. These securities are directly purchased from or sold to a financial services firm acting as a dealer (or principal). A dealer executing such trades may include a commission, a markup (on securities it sells), a markdown (on securities it buys) or a spread (the difference between the price it will buy or “bid” for the security and the price at which it will sell or “ask” for the security) in the net price at which transactions are executed. The bid and ask are prices quoted by the dealer, so you should understand that a dealer’s bid price would be the price at which a client is selling their security, and the dealer’s ask price would be the price at which a client is buying the security.

You should review an Investment Manager’s Form ADV Part 2A Brochure, ask about an Investment Manager’s trading practices, and consider that information carefully before selecting an Investment Manager and its investment strategy. In particular, you should carefully consider any additional trading costs associated with a particular Investment Manager and investment strategy before selecting them for your Wrap Fee Program account.

JPMS Wrap Fee Programs Trading Away Information 
Set forth below is certain summary trading away information for Investment Managers in the Wrap Fee Programs. The information for each Investment Manager has been provided to JPMS by that Investment Manager, and JPMS does not guarantee its accuracy.  You should consult each Investment Manager’s Form ADV Part 2A brochure and/or contact your J.P. Morgan Securities Financial Advisor to obtain additional information about an Investment Manager’s trading away practices.
An Investment Manager’s past trading away practice is not a guarantee that such Investment Manager will follow the same practice in the future.

Trading Away: STRATIS

January – December 2017

* Investment Strategies that invest in foreign securities may incur additional costs assessed by the exchange(s) on which trades were executed, such as exchange fees and taxes, and may also incur costs such as ADR conversion fees and currency conversion costs which may be reflected in the aggregate additional costs figures below. For example, an Investment Manager may purchase a security via “ordinary shares” on a foreign exchange (which may charge a fee or tax on that trade), and then the bank may charge a fee to convert the ordinary shares into American Depository Receipts (“ADR(s)”), and there may be currency conversion costs associated with this ordinary-to-ADR conversion.

As a result, the aggregate additional cost figures below are generally higher for Investment Strategies that invest in foreign securities than for Investment Strategies that trade primarily in ADR securities (without first purchasing and subsequently converting ordinary foreign shares) on U.S. exchanges or OTC markets. The below aggregate additional cost figures include disclosure to reflect if additional ADR conversion and/or currency conversion costs were incurred and included.

Firm Strategy Dollar-weighted % of client trades “traded away” Aggregate additional cost incurred by clients participating in those trades* (cps = cents per share)
AMG Funds LLC US Equity Mid Cap Core 0.00% $0.0000
Appleton Partners, Inc. US Tax-Exempt Fixed Income 100.00% $0.0000
Appleton Partners, Inc. US Tax-Exempt Fixed Income - Short Term 100.00% $0.0000
Atlanta Capital Management US Equity Small Cap Core 56.00% $0.0000
Atlanta Capital Management US Equity Small/Mid Cap Core 66.00% $0.0000
Baird Investment Management US Equity Mid Cap Growth 94.00% $0.0000
BlackRock Investment Management, LLC US Tax-Exempt Fixed Income 100.00% $0.0000
Boston Partners Global Investors Inc. US Equity Large Cap Value 0.00% $0.0000
Boston Partners Global Investors Inc. US Equity Mid Cap Value 0.00% $0.0000
Brown Advisory LLC US Equity Small Cap Growth 0.00% $0.0000
Capital Group Global Equity* 11.00% 2-12 cents per share
Capital Group International Equity* 36.00% 2-12 cents per share
Congress Asset Management Company, LLP US Equity Mid Cap Growth 0.00% $0.0000
Copeland Capital Management, LLC US Equity Small/Mid Cap Core 0.00% $0.0000
Delaware Management Business Trust International Equity* 41.05% 6 Basis Points commission
Diamond Hill Capital Management, Inc. US Equity Large Cap Value 0.00% $0.0000
EARNEST Partners, LLC US Equity Mid Cap Value 0.00% $0.0000
Federated Investment Counseling US Equity Large Cap Value 5.60% $0.0000
Fiduciary Management, Inc. US Equity Large Cap Core 0.00% $0.0000
Fred Alger Management US Equity Large Cap Growth 0.00% $0.0000
Glenmede Investment Management LP US Equity Small Cap Core 0.00% $0.0000
Golden Capital Management, LLC US Equity Large Cap Core 0.00% $0.0000
GW&K Investment Management, LLC US Equity Small Cap Core 0.00% $0.0000
GW&K Investment Management, LLC US Equity Small/Mid Cap Core 0.00% $0.0000
GW&K Investment Management, LLC US Tax Exempt Fixed Income 100.00% $0.0000
GW&K Investment Management, LLC US Taxable Fixed Income 100.00% $0.0000
Harding Loevner LP International Equity* 44.00% 6.7 Basis Points
Invesco Advisers, Inc. US Equity Large Cap Value 0.00% $0.0000
J.P. Morgan Investment Management Inc. US Equity All-Cap Growth 0.00% $0.0000
J.P. Morgan Investment Management Inc. US Equity Large Cap Growth 0.00% $0.0000
J.P. Morgan Investment Management Inc. US Equity Mid Cap Value 0.00% $0.0000
J.P. Morgan Investment Management Inc. US Tax Exempt Fixed Income 100.00% $0.0000
J.P. Morgan Private Investments Inc US Equity All Cap Core (Focused Tactical Equity) 0.00% $0.0000
J.P. Morgan Private Investments Inc US Equity Large Cap Core (Focused Dividend Growth) 0.00% $0.0000
John Hancock Asset Management US Equity Large Cap Core 0.00% $0.0000
Kayne Anderson Rudnick Investment Management, LLC US Equity Small Cap Value 32.00% $0.0300
Kayne Anderson Rudnick Investment Management, LLC US Equity Small/Mid Cap Core 7.00% $0.0400
Lazard Asset Management Diversified Income - Other Income 90% - 100% $0.03 plus $0.04 to $0.05 ADR Conversion Fees
Lazard Asset Management LLC Emerging Markets Equity* 90% - 100% $0.03 plus $0.04 to $0.05 ADR Conversion Fees
Lazard Asset Management LLC Emerging Markets Equity (Asia ex Japan)* 90% - 100% $0.03 plus $0.04 to $0.05 ADR Conversion Fees
Lazard Asset Management LLC Emerging Markets Equity (Developing Markets)* 90% - 100% $0.03 plus $0.04 to $0.05 ADR Conversion Fees
Legg Mason Private Portfolio Group, LLC US Equity All Cap Growth (Multi Cap Growth) 2.48% $0.0043
Legg Mason Private Portfolio Group, LLC US Equity Large Cap Core (Appreciation ESG) 54.64% $0.0123
Legg Mason Private Portfolio Group, LLC US Equity Large Cap Core (Appreciation Strategy) 48.15% $0.0118
Legg Mason Private Portfolio Group, LLC US Equity Large Cap Core (Dividend Strategy) 50.73% $0.0139
LMCG Investments, LLC US Equity Small Cap Value 0.00% $0.0000
Lord, Abbett & Co. US Tax Exempt Fixed Income 100.00% $0.0000
Madison Investment Advisors, LLC US Taxable Fixed Income - Intermediate 100.00% $0.0000
Madison Investment Advisors, LLC US Taxable Fixed Income Intermediate (Corporate Only) 100.00% $0.0000
NGAM Advisors, L.P. (NATIXIS) Real Estate Securities 0.00% $0.0000
NGAM Advisors, L.P. (NATIXIS) US Equity Large-Cap Growth (Loomis Sayles) 0.00% $0.0000
Nuveen Asset Management, LLC Specialty - Preferred Securities 100% Commission on the $25 par of 1 cent.  No commission on the $1000 par
O'Shaughnessy Asset Management, LLC International Equity* 0.00% $0.0000
O'Shaughnessy Asset Management, LLC International 0.00% $0.0000
O'Shaughnessy Asset Management, LLC All-Cap Core 0.00% $0.0000
Pacific Investment Management Company (PIMCO) Multi Strategy Fixed Income 100.00% $0.0000
Polen Capital Management Large-Cap Growth 0.02% $0.0000
Renaissance Investment Management Large Cap Growth 0.00% $0.0000
Riverbridge Partners, LLC US Equity All-Cap Growth 0.00% $0.0000
Riverbridge Partners, LLC US Equity Small Cap Growth 0.00% $0.0000
Riverbridge Partners, LLC US Equity Small/Mid Cap Growth 0.00% $0.0000
Sage Advisory Services, Ltd. Co. US Taxable Fixed Income - Intermediate 100.00% $0.0000
Schafer Cullen Capital Management, Inc. International Equity* 10.29% $0.02000
Schafer Cullen Capital Management, Inc. US Equity Large Cap Value 5.01% $0.0000
Seix Investment Advisors LLC High Yield Fixed Income 100.00% $0.0000
SouthernSun Asset Management LLC US Equity Small/Mid Cap Core 0.00% $0.0000
Sterling Capital Management LLC US Equity Mid Cap Value 0.00% $0.0000
TCW Investment Management Company US Equity Large Cap Growth 0.00% $0.0000
Templeton Portfolio Advisors, Inc. International Equity* 34.00% $0.0075 – $0.0100
The London Company of Virginia, LLC US Equity Large Cap Core 0.00% $0.0000
Tributary Capital Management, LLC US Equity Small Cap Core 0.00% $0.0000
Uniplan Real Estate Advisors, Inc. (Uniplan Investment Counsel) Real Estate Securities Less than 1% $0.0000
Uniplan Real Estate Advisors, Inc. (Uniplan Investment Counsel) Specialty (HITR K1) Less than 1% $0.0000
Uniplan Real Estate Advisors, Inc. (Uniplan Investment Counsel) Specialty (HITR Non-K1) Less than 1% $0.0000
WCM Investment Management International Equity* 0.00% $0.0000
WCM Investment Management Global Equity 0.00% $0.0000
Wedgewood Partners, Inc. US Equity Large Cap Growth 0.00% $0.0000
Wells Fargo Funds Management Large-Cap - S&P 500 0.00% $0.0000
Wells Fargo Funds Management, LLC US Equity Small/Mid Cap Growth 0.00% $0.0000
Winslow Capital Management, LLC US Equity Large Cap Growth 0.00% $0.0000
J.P. Morgan Investment Management Inc. US Equity Mid Cap Growth 0.00% $0.0000

Trading Away: ICS

January – December 2017

Certain strategies may not be available for new clients

* Investment Strategies that invest in foreign securities may incur additional costs assessed by the exchange(s) on which trades were executed, such as exchange fees and taxes, and may also incur costs such as ADR conversion fees and currency conversion costs which may be reflected in the aggregate additional costs figures below. For example, an Investment Manager may purchase a security via “ordinary shares” on a foreign exchange (which may charge a fee or tax on that trade), and then the bank may charge a fee to convert the ordinary shares into American Depository Receipts (“ADR(s)”), and there may be currency conversion costs associated with this ordinary-to-ADR conversion.

As a result, the aggregate additional cost figures below are generally higher for Investment Strategies that invest in foreign securities than for Investment Strategies that trade primarily in ADR securities (without first purchasing and subsequently converting ordinary foreign shares) on U.S. exchanges or OTC markets. The below aggregate additional cost figures include disclosure to reflect if additional ADR conversion and/or currency conversion costs were incurred and included.

Firm Strategy Dollar-weighted % of client trades “traded away” Aggregate additional cost incurred by clients participating in those trades* (cps = cents per share)
12th Street Opportunity (NATIXIS STRATEGY) US Equity All-Cap Value - S&P 500 0.00% $0.0000
12th Street Opportunity All-Cap Value - S&P 500 0.00% $0.0000
Akre Capital Management, LLC US Equity All-Cap Value 0.00% $0.0000
Apex Capital Management LLC US Equity Small-to-Mid-Cap Growth 0.00% $0.0000
Appleton Partners, Inc. US Taxable Fixed Income - Market Duration 100.00% $0.0000
Appleton Partners, Inc. US Tax-Exempt Fixed Income 100.00% $0.0000
Appleton Partners, Inc. US Tax-Exempt Fixed Income - Short Term 100.00% $0.0000
Asset Preservation Advisors Inc US Tax-Exempt Fixed Income 100.00% $0.0000
BlackRock Investment Management, LLC US Taxable Fixed Income Short Term 100.00% $0.0000
Bramshill Investments, LLC US Taxable Fixed Income  - Aggregate Index 100.00% $0.0000
Chickasaw Capital Management, LLC Specialty - Master Limited Partnership (MLP) 0.00% $0.0000
Columbia Management Investment Advisers, LLC US Equity Large-Cap Value 0.00% $0.0000
Congress Asset Management Company, LLP US Taxable Fixed Income Intermediate 0.00% $0.0000
Credit Suisse Asset Management, LLC Cash Management 100.00% $0.0000
Credit Suisse Asset Management, LLC US Tax-Exempt Fixed Income 100.00% $0.0000
Dana Investment Advisors Inc US Equity Large-Cap Value 0.00% $0.0000
Davis Capital Advisors, LLC US Equity Large-Cap - S&P 500 0.00% $0.0000
Dolan McEniry Capital Management LLC US Taxable Fixed Income  - Aggregate Index 100.00% $0.0000
Dolan McEniry Capital Management LLC US Taxable Fixed Income Intermediate (Corporate Only) 100.00% $0.0000
Eaton Vance US Tax-Exempt Fixed Income Intermediate 100.00% $0.0000
Fayez Sarofim & Co Large-Cap Growth 0.00% $0.0000
Fiduciary Management, Inc. US Equity Large Cap Core 0.00% $0.0000
Forward Management, LLC US Equity Large-Cap - S&P 500 0.00% $0.0000
Forward Management, LLC US Equity Large-Cap Value 0.00% $0.0000
GAMCO Investors, Inc. US Equity All-Cap Value - S&P 500 0.00% $0.0000
Geneva Advisors, LLC US Equity All-Cap Growth 0.00% $0.0000
Glovista Investments LLC Emerging Markets Equity* 0.00% $0.0000
Grand-Jean Capital Management US Equity All-Cap Core 0.00% $0.0000
Granite Investment Partners LLC US Equity Large-Cap Growth 0.00% $0.0000
Gurtin Municipal Bond Management US Tax-Exempt Fixed Income 6 Barclays 3-15y 100.00% $0.0000
GW&K Investment Management, LLC US Tax Exempt Fixed Income 100.00% $0.0000
GW&K Investment Management, LLC US Taxable Fixed Income Aggregate 100.00% $0.0000
Hamlin Capital Management High Yield-Muni 100.00% $0.0000
Harvest Funds LLC Specialty - Master Limited Partnership (MLP) 0.00% $0.0000
Haverford Financial Services, Inc. US Equity Large-Cap - S&P 500 0.00% $0.0000
Horizon Asset Management LLC US Equity Large Cap Value - S&P 0.00% $0.0000
Horizon Asset Management LLC US Equity Large-Cap - S&P 500 0.00% $0.0000
Horizon Asset Management LLC US Equity Large-Cap Core 0.00% $0.0000
Horizon Asset Management LLC US Equity Large-Cap Value 0.00% $0.0000
JAG Capital Management LLC Large-Cap Growth 0.00% $0.0000
JAG Capital Management LLC US Equity Large-Cap Growth 100.00% $0.0000
JAG Capital Management LLC US Taxable Fixed Income 100.00% $0.0000
Kayne Anderson Rudnick Investment Management, LLC US Equity Small Cap Core 37.00% $0.0400
LDR Capital Management, LLC Specialty - Preferred Securities 100.00% $0.0000
Legg Mason Private Portfolio Group, LLC US Equity All Cap Growth 79.50% $0.0155
Legg Mason Private Portfolio Group, LLC US Equity All Cap Growth (Multi Cap Growth) 16.23% $0.0139
Legg Mason Private Portfolio Group, LLC US Equity Large Cap Core - Appreciation ESG 100.00% $0.0121
Madison Investment Advisors, LLC US Taxable Fixed Income - Intermediate 100.00% $0.0000
Madison Investment Advisors, LLC US Taxable Fixed Income Intermediate (Corporate Only) 100.00% $0.0000
MBSC Securities Newton Global Equity Income 0.93% Commission ranges from 0-4 cents per share or 0-10Basis Points
Miller Howard Investments Inc All-Cap Value 0.00% $0.0000
Miller Howard Investments Inc Emerging Markets Equity* 0.00% $0.0000
Miller Howard Investments Inc Specialty - Master Limited Partnership (MLP) 0.00% $0.0000
Miller Howard Investments Inc US Equity Large-Cap Core 0.00% $0.0000
Miller Howard Investments Inc US Equity Large-Cap Value 0.00% $0.0000
Morris Capital Advisors LLC US Equity Large-Cap Growth 0.00% $0.0000
Mount Lucas Management LP US Equity Large Cap Value - S&P 0.00% $0.0000
Municipal Portfolio Managers, Inc. US Tax-Exempt Fixed Income 100.00% $0.0000
Natixis - AIA Large Cap Core 0.00% $0.0000
Natixis - Cornerstone US Equity Large-Cap - S&P 500 0.00% $0.0000
Natixis - Morgan Dempsey US Equity Small-Cap Value 0.00% $0.0000
Natixis - MRP US Equity Small Cap Core 0.00% $0.0000
Natixis CSAM European Equity* 0.00% $0.0000
Natixis CSAM European Equity Sustainable Dividend* 0.00% $0.0000
Natixis CSAM Global All World Equity Sustainable Dividend* 0.00% $0.0000
Natixis CSAM Global Equity Sustainable Dividend* 0.00% $0.0000
Natixis Lateef US Equity All-Cap Growth 0.00% $0.0000
Natixis Sterling US Equity All Cap Equity Core 0.00% $0.0000
Natixis Sterling US Equity Large-Cap Value 0.00% $0.0000
Neuberger Berman US Equity Large-Cap - S&P 500 (Bolton) 0.00% $0.0000
Neuberger Berman Master Limited Partnership (MLP) 0.00% $0.0000
Nuveen Asset Management Municipal Bonds 100.00% Approximately 1-10 basis points
Nuveen Asset Management US Tax-Exempt Fixed Income 6 Barclays 3-15y 100.00% Approximately 1-10 basis points
NWQ Investment Management Company, LLC International Equity Value* 0.00% $0.0000
NWQ Investment Management Company, LLC US Equity All-Cap Value 0.00% $0.0000
NWQ Investment Management Company, LLC US Equity Large-Cap Value 0.00% $0.0000
Oppenheimer Asset Management, Inc. US Taxable Fixed Income - Market Duration 100.00% $0.0000
O'Shaughnessy Asset Management, LLC US Equity Small-Cap Growth 0.00% $0.0000
O'Shaughnessy Asset Management, LLC Market Leaders Value 0.00% $0.0000
Parametric Portfolio Associates LLC Custom Core Fossil Free International 0.00% $0.0000
Parametric Portfolio Associates LLC 60/40 US/INTL EQUITY 0.00% $0.0000
Parametric Portfolio Associates LLC International Equity Core* 0.00% $0.0000
Parametric Portfolio Associates LLC 60/40 US Equity All Cap/ Intl Equity 0.00% $0.0000
Parametric Portfolio Associates LLC Specialty - Delta Shift 0.00% $0.0000
Parametric Portfolio Associates LLC US Equity All-Cap Core 0.00% $0.0000
Parametric Portfolio Associates LLC US Equity Large-Cap - S&P 500 0.00% $0.0000
Parametric Portfolio Associates LLC US Equity Large-Cap Core 0.00% $0.0000
Parametric Portfolio Associates LLC US Equity Mid-Cap Value 0.00% $0.0000
Payden & Rygel US Taxable Fixed Income Core 100.00% $0.0000
Payden & Rygel US Taxable Fixed Income Low Duration 100.00% $0.0000
Principal Global Investors, LLC Specialty - Preferred Securities 20-25% $0.0000
Principal Global Investors, LLC US Equity Mid Cap Core 0.00% $0.0000
RNC Capital Management LLC US Taxable Fixed Income Intermediate 100.00% $0.0000
RNC Capital Management LLC US Tax-Exempt Fixed Income 100.00% $0.0000
Roosevelt Investment Group Balanced Core 14.80% $0.0000
RSW Investments, LLC US Tax-Exempt Fixed Income 100.00% $0.0000
Santa Barbara Asset Management LLC Focused Dividend Growth 0.00% $0.0000
Sawgrass Asset Management Small-Cap Growth 0.00% $0.0000
Schafer Cullen Capital Management, Inc. Emerging Markets Equity* 60.20% 2-3 cents per share for some trades
Schafer Cullen Capital Management, Inc. International Equity* 10.29% 2 cents per share for some trades
Schafer Cullen Capital Management, Inc. Specialty Equity 0.00% $0.0000
Schafer Cullen Capital Management, Inc. US Equity Large Cap Value 5.01% $0.0000
Seizert Capital Partners, LLC US Equity Mid Cap Core 0.00% $0.0000
Shenkman Capital Management, Inc. Convertibles 100.00% $0.0000
Systematic Financial Management LP US Equity Small-Cap Value 0.00% $0.0000
Systematic Financial Management LP US Equity Small-Cap Value Focus 0.00% $0.0000
The London Company of Virginia, LLC US Equity Small Cap Core 0.00% $0.0000
The Renaissance Group LLC US Equity Large-Cap Growth 0.00% $0.0000
Tocqueville Asset Management International Equity Core* 75.00% $0.0000
Tocqueville Asset Management Balanced Core 75.00% $0.0000
Tocqueville Asset Management Balanced Neutral 75.00% $0.0000
Tocqueville Asset Management US Equity Large-Cap - S&P 500 75.00% $0.0000
Uniplan Diversified Equity High Income Opportunity 0.00% $0.0000
Uniplan US Equity Micro Cap Core Equity 0.00% $0.0000
Victory Capital Management Inc. US Equity Large-Cap Growth 0.00% $0.0000
Volaris Capital Management LLC Single Leg Options 100.00% $0.80/contract is electronic broker commission. The majority is to cover exchange fees.

Trading Away: UMA

January – December 2017

Please note that (a) Envestnet Asset Management (“Envestnet”) is the Overlay Manager for all strategies in the Program, (b) the 0% shown for Envestnet applies to the equity strategies for which Envestnet alone has investment discretion, and (c) Envestnet and the other managers shown have joint investment discretion for the fixed income strategies.

Firm Strategy Dollar-weighted % of client trades “traded away” Aggregate additional cost incurred by clients participating in those trades* (cps = cents per share)
Appleton Partners, Inc. US Tax-Exempt Fixed Income 100.00% $0.0000
Appleton Partners, Inc. US Tax-Exempt Fixed Income - Short Term 100.00% $0.0000
Envestnet Asset Management UMA 0.00% $0.0000
GW&K Investment Management, LLC US Tax Exempt Fixed Income 100.00% $0.0000
GW&K Investment Management, LLC US Taxable Fixed Income 100.00% $0.0000
Madison Investment Advisors, LLC US Taxable Fixed Income - Intermediate 100.00% $0.0000
Madison Investment Advisors, LLC US Taxable Fixed Income Intermediate (Corporate Only) 100.00% $0.0000
Sage Advisory Services, Ltd. Co. US Taxable Fixed Income - Intermediate 100.00% $0.0000
Sage Advisory Services, Ltd. Co. US Taxable Fixed Income - Intermediate 100.00% $0.0000
Seix Investment Advisors LLC High Yield Fixed Income 100.00% $0.0000

Trading Away: C-BoS

The C-BoS Program launched in January 2018; therefore, there is no information to be provided for 2017.

Trading Away: SMA

January – December 2017

Firm Strategy Dollar-weighted % of client trades “traded away” Aggregate additional cost incurred by clients participating in those trades* (cps = cents per share)
O'Shaughnessy Asset Management, LLC International Equity* 0.00% $0.0000
O'Shaughnessy Asset Management, LLC All-Cap Core 0.00% $0.0000

Last Updated April 23, 2018

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The views and strategies described may not be suitable for all investors. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors before engaging in any transaction. Securities are offered by J.P. Morgan Securities LLC. ("JPMS"), member FINRA and SIPC. When JPMS acts as a broker-dealer, a client's relationship with us and our duties to the client will be different in some important ways than a client's relationship with us and our duties to the client when we are acting as an investment advisor. A client should carefully read the agreements and disclosures received (including our Form ADV disclosure brochure, if and when applicable) in connection with our provision of services for important information about the capacity in which we will be acting.

This document provides information about the brokerage and investment advisory services provided by J.P. Morgan Securities LLC ("JPMS"). The agreements entered into by and disclosures provided to clients with respect to the different products and services provided by JPMS should be carefully read (including our Form ADV disclosure brochure, if and when applicable), which contain important information, including our provision of services for important information about the capacity in which we will be acting. We encourage clients to speak to their JPMS representative regarding the nature of the products and services and to ask any questions they may have about the difference between brokerage and investment advisory services, including the obligation to disclose conflicts of interests and to act in the best interests of our clients.

Annuities are made available through Chase Insurance Agency, Inc. (CIA), a licensed insurance agency, doing business as Chase Insurance Agency Services, Inc. in Florida. JPMCB, JPMS and CIA are affiliated companies under the common control of JPMorgan Chase & Co. Products not available in all states.

“J.P. Morgan Securities” is a brand name for a wealth management business conducted by JPMorgan Chase & Co (“JPMC”) and its subsidiaries worldwide. JPMorgan Chase Bank, N.A. and its affiliates (collectively “JPMCB”) offer investment products, which may include bank-managed accounts and custody, as part of its trust and fiduciary services. Other investment products and services, such as brokerage and advisory accounts, are offered through J.P. Morgan Securities LLC (JPMS), a member of FINRA and SIPC. JPMCB and JPMS are affiliated companies under the common control of JPMorgan Chase & Co.

INVESTMENT PRODUCTS:
• NOT FDIC INSURED • NO BANK GUARANTEE • MAY LOSE VALUE

 
 

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