Disclosures

Consulting Services Group, LLC (CSG) is an investment adviser that is registered with the Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940. Commerce Square Trading, LLC (CST) is a broker-dealer that offers investment products and services and is a member of FINRA and SIPC. InterSec Research, LLC (InterSec) is a research consulting firm. Commerce Advisors, LLC (CA) is an investment adviser that is registered with the Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940. CA is wholly owned by Commerce Holdings, LLC. Commerce Asset Management LLC (CAM) is an investment adviser that is registered with the Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940. CAM is an affiliated entity formed by Commerce Holdings, LLC to provide investment management services in respect of various types of investments. CAM owns 85% of Quantitative Alternative Management, LLC (QAM). QAM was formed by CAM to provide investment management services in respect of various types of alternative investment replication products.

Consulting Services Group, LLC, Commerce Holdings, LLC (parent company of related investment advisers Commerce Advisors, LLC and Commerce Asset Management LLC), Commerce Square Trading, LLC,and InterSec Research, LLC are each wholly-owned by CSG Holdings, LLC.

CSG, CST, InterSec, CA and CAM do not provide legal or tax advice to clients. All clients with tax considerations, including the effect of UBTI resulting from alternative investment strategies, are strongly urged to consult their tax advisers regarding such issues. A copy of CSG, CA or CAM's current ADV Brochures may be obtained by contacting the firm's compliance department at 901.761.8080 or at www.sec.gov.