CHANDLER ASSET MANAGEMENT INC

ITEM 1 – COVER PAGE Part 2A of Form ADV: Firm Brochure Chandler Asset Management, Inc. 9255 Towne Centre Drive Suite 600 San Diego, CA 92121 Telephone: 858-546-3737 Email: compliance@chandlerasset.com Web Address: www.chandlerasset.com September 8, 2025 This disclosure brochure (the “Brochure”) provides information about the qualifications and business practices of Chandler Asset Management, Inc. (“Chandler”). If you have any questions about the contents of this Brochure, please contact us at 858-546-3737 or compliance@chandlerasset.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC does not imply any level of skill or training. Additional information about Chandler and its investment adviser representatives is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by name or by a unique identifying number, known as a CRD number. Our firm's CRD number is 107287.  ITEM 2 – MATERIAL CHANGES This Firm Brochure, dated September 8, 2025, provides you with a summary of Chandler's advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This item (Item 2) is used to provide our clients with a summary of new and/or updated information; we will inform you of the revision(s) based on the nature of the information as follows. 1. Annual Update: We are required to update certain information at least annually, within 90 days of our firm’s fiscal year end (“FYE”) of December 31. We will provide you with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of our FYE or we will provide you with our revised Brochure that will include a summary of those changes in this Item. 2. Material Changes: Should a material change in our operations occur, depending on its nature we will promptly communicate this change to clients (and it will be summarized in this Item). “Material changes” requiring prompt notification will include changes of ownership or control; location or disciplinary proceedings. We may also advise you of other changes based on the nature of the updated information. The following summarizes new or revised disclosures. • • Brochure – Effective August 12, 2025, Chandler was appointed as investment adviser to the California Fixed Income Trust. This Brochure has expanded its discussions around its roles and responsibilities when acting as an investment adviser to local government investment pools. Participants in these pools should pay special attention to the discussion around conflicts of interest provided for Item 11A of this brochure. Item 4 and Item 5 – This Brochure has been updated to more clearly discuss certain Reporting Services provided by Chandler. Clients and prospective clients are strongly encouraged to review this Brochure very carefully. 1 | P a g e  ITEM 3 – TABLE OF CONTENTS Item 1 – Cover Page ...................................................................................................................................... 0 Item 2 – Material Changes ............................................................................................................................ 1 Item 3 – Table of Contents ............................................................................................................................ 2 Item 4 – Advisory Business .......................................................................................................................... 4 Item 4A: Firm Overview ........................................................................................................................... 4 Item 4B: Types of Advisory Services ........................................................................................................ 4 Item 4C: Tailoring Advisory Services Offered Directly to Clients ........................................................... 5 Item 4E: Assets Under Management ......................................................................................................... 6 Item 5 – Fees and Compensation .................................................................................................................. 6 Item 5A: Fee Schedules ............................................................................................................................ 6 Item 5B: Fee Payment ............................................................................................................................... 8 Item 5C: Other Fees and Expenses and Valuation Policy ......................................................................... 8 Item 5D: Prepaid Fees ............................................................................................................................... 9 Item 5E: Compensation for the Sale of Securities or Investment Products ............................................ 10 Item 6: Performance-Based Fees and Side-by-Side Management .............................................................. 10 Item 7: Types of Clients .............................................................................................................................. 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 10 Item 8A: Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 10 Item 8B: Material Risks .......................................................................................................................... 15 Item 8C: Risks Associated with Particular Types of Securities Used ..................................................... 15 Item 9 – Disciplinary Information .............................................................................................................. 18 Item 10 – Other Financial Industry Activities and Affiliations ................................................................... 18 Item 11 – Code of Ethics, Particiption or Interest in Client Transactions and Personal Trading ................ 19 Item 11A: Code of Ethics ........................................................................................................................ 19 Item 11B: Principal Trading and Agency Cross Trading ........................................................................ 19 Item 11C: Personal Trading .................................................................................................................... 20 Item 11D: Participation or Interest in Client Transactions ...................................................................... 20 Item 12 – Brokerage Practices .................................................................................................................... 21 Item 12A: Broker-Dealer Selection, Compensation & Trade Aggregation ............................................ 21 Item 12A.1: Soft Dollar Arrangements and Other Benefits .................................................................... 21 Item 12A.2: Research from Approved Brokers ...................................................................................... 21 Item 12A.3: Brokerage for Client Referrals ............................................................................................ 22 Item 12A.4: Directed Brokerage ............................................................................................................. 22 2 | P a g e  Item 12B: Aggregating Client Trades ..................................................................................................... 22 Item 13 – Accounts Reviews ....................................................................................................................... 24 Item 13A: Periodic Account Reviews ..................................................................................................... 24 Item 13B: Other Reviews ........................................................................................................................ 24 Item 13C: Reporting ............................................................................................................................... 24 Item 14 – Client Referrals and Other Compensation .................................................................................. 25 Item 14A: Other Compensation .............................................................................................................. 25 Item 15 – Custody ....................................................................................................................................... 25 Item 16 – Investment Discretion ................................................................................................................. 26 Item 17 – Voting Client Securities .............................................................................................................. 26 Item 17A: Proxy Voting .......................................................................................................................... 26 Item 17B: Where Client Retains Right to Vote Proxies .......................................................................... 27 Item 18 – Financial Information ................................................................................................................. 27 Item 18A: Financial Statement Requirement .......................................................................................... 27 Item 18B: Financial Condition ................................................................................................................ 27 Item 18C: Bankruptcy Disclosure ........................................................................................................... 27 3 | P a g e  ITEM 4 – ADVISORY BUSINESS ITEM 4A: FIRM OVERVIEW Chandler Asset Management, Inc. (“Chandler”) is an SEC-registered investment adviser and employee- owned business enterprise with its principal place of business located in San Diego, California. Since 1988, Chandler has provided fixed income investment management services to the public sector, as well as to hospitals, foundations, endowments, and corporations. Chandler is wholly owned by Chandler Investor Services, Inc. which, in turn, is owned by the Chandler Asset Management, Inc. Employee Stock Ownership Plan (“ESOP”), Martin Cassell, CFO and Chairman of the Board, and other individuals (all owning less than 25% of Chandler Investor Services, Inc.). Chandler is under common ownership and control with Chandler Distribution Services, LLC, a registered broker- dealer, please refer to Item 10 for additional information. ITEM 4B: TYPES OF ADVISORY SERVICES Chandler offers the following advisory services, where appropriate, to certain institutional clients such as public agencies, hospitals and healthcare institutions, corporations or other business entities, foundations and endowments, pension and profit-sharing plans, higher education institutions, local government investment pools, and charitable organizations. The portfolio management services are offered to clients directly. FIXED INCOME PORTFOLIO MANAGEMENT Chandler specializes in fixed income portfolio management, utilizing a variety of investments, such as corporate debt securities (notes and bonds), municipal bonds, U.S. Government Treasury bonds, government sponsored enterprise debt securities (agencies), mortgage-backed securities, asset-backed securities and money market securities, i.e., commercial paper. Please refer to Item 8 for further information on our method of analysis and risks associated with this strategy. MULTI ASSET CLASS PORTFOLIO MANAGEMENT Chandler also offers a Multi Asset Class strategy to clients seeking to attain exposure to a variety of global equity, fixed income and other asset classes through investment in indexed or actively managed mutual funds and exchange-traded funds (“ETFs”). Please refer to Item 8 for further information on our method of analysis and risks associated with this strategy. LOCAL GOVERNMENT INVESTMENT POOLS The Florida Surplus Asset Fund Trust (“FL SAFE”) – Chandler provides investment management services to a suite of funds offered by FL SAFE – a Florida Local Government Investment Pool. FL SAFE is organized under Florida state law and its participants consist of local government entities such as school districts, community colleges, counties, municipalities and other units of local government. Participants in FL SAFE should carefully review the FL SAFE Information Statement, which is available on the FL SAFE website, for more details regarding the risks and characteristics of a specific FL SAFE pool. Please refer to Item 8 for further information on our method of analysis and risks associated with this strategy. The California Fixed Income Trust (“CalFIT”) – Chandler provides investment management services to CalFIT – a California Local Government Investment Pool. CalFIT is organized under California state law and its participants consist of local government entities such as school districts, community colleges, counties, municipalities and other units of local government. Participants in CalFIT should carefully review the CalFIT Information Statement, which is available on the CalFIT website, for more details regarding the 4 | P a g e  risks and characteristics of a specific CalFIT pool. Please refer to Item 8 for further information on our method of analysis and risks associated with this strategy. Administrative Services – As discussed in Item 10, Chandler also acts as an administrative capacity to both FL SAFE and CalFIT and is entitled to certain fees for those services. Affiliated Broker-Dealer – Item 10 discusses the marketing and distribution role that Chandler Distribution Services, LLC, Chandler’s affiliated broker-dealer, performs relation to both FL SAFE and CalFIT pools to which Chandler also acts as investment manager (discussed above). Further, Item 11 discusses certain conflicts of interests that may arise from these brokerage activities. CONSULTING SERVICES Chandler provides more focused investment advice to clients. This advice can pertain to areas that clients consider a concern, such as analysis of a client’s existing portfolio, delivery of a report or periodic reports of performance and recommended rebalancing of assets, or a review of the client’s investment policy. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer. REPORTING SERVICES Chandler may provide clients with reports that combine information from all their investment accounts, whether Chandler manages them or they are managed elsewhere. These reports may include details like account balances, holdings, transactions, performance, and other financial information. Chandler’s reporting services are designed to give clients a consolidated view of their investment portfolios. However, when reporting on accounts not managed by Chandler, we rely on information provided by the client, custodians, or third-party investment managers and Chandler does not independently verify the accuracy of such information. Reporting services are intended solely for client informational purposes and should not be construed as individualized investment advice with respect to non-managed accounts. Clients utilizing reporting services should continue to rely on the official statements and records provided by custodians or other account managers for tax reporting, trade confirmations, and official account data. ESG REPORTING SERVICES Chandler provides environmental, social and governance reporting services (“ESG Reporting Services”) to clients on a negotiated basis. ESG Reporting Services may include data collection, analysis, and preparation of reports on environmental impact, social responsibility, and governance practices of investments held by the clients in portfolios managed by Chandler. Such reports will typically be distributed on a quarterly basis or as otherwise mutually agreed upon. In offering these services, Chandler relies on third parties which we deem reliable, but Chandler makes no warranties as to the information provided. ITEM 4C: TAILORING ADVISORY SERVICES OFFERED DIRECTLY TO CLIENTS At the beginning of the client relationship, we have discussions with clients to determine their overall investment goals, to develop a specific investment policy for each client (as needed) and confirm that the selected strategy meets their current needs. During our information gathering process, we review the client’s individual objectives, time horizons, risk tolerance, liquidity needs and any investment restrictions they may want to place on the assets in their account. As appropriate, we also review and discuss a client's prior investment history, and any other relevant issues. Once these reviews and discussions take place, the client enters into a written agreement directly with Chandler for advisory services. 5 | P a g e  Clients are responsible for informing us of any changes to their guidelines, individual needs and/or restrictions and should do so promptly upon such change. We do not assume any responsibility for the accuracy of the information provided by the client. Generally, we manage clients’ advisory accounts on a discretionary basis but will manage a client’s account on a non-discretionary basis, if requested by a client. Please refer to Item 16 for further information on our discretionary authority of client accounts. In addition to the types of securities utilized by Chandler for its Fixed Income Portfolio Management and Multi Asset Class Portfolio Management services outlined above, we also provide advice on or manage other investments for clients, particularly when a client already has securities in his/her portfolio at the time the client opens an account with Chandler. These generally include, but are not limited to: • Exchange-listed securities • Securities traded over-the-counter • Certificates of deposit Some types of investments involve certain additional degrees of risk; therefore, they will only be implemented or recommended when consistent with the client's stated investment goals, tolerance for risk, liquidity and suitability requirements. Please refer to Item 8 for further information on the risks associated with investments made in clients’ accounts. Clients will always retain individual ownership of all securities through their selected custodian. ITEM 4E: ASSETS UNDER MANAGEMENT As of December 31, 2024, Chandler had $41,582,938,832 in assets under management, of which $33,990,769,058 being managed on a discretionary basis and $7,592,169,774 being managed on a non- discretionary basis. ITEM 5 – FEES AND COMPENSATION ITEM 5A: FEE SCHEDULES The annual fee for client accounts is charged as a percentage of assets under management, according to the following schedules: Fixed Income Portfolio Management Assets Under Management All Assets Annual Asset Management Fee 0.15 of 1% (15 basis points) A minimum of $20 million in assets under management is required for this service. Chandler reserves the right to negotiate alternative minimum account size and fees on a case-by-case basis. Chandler will aggregate certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Multi Asset Class Portfolio Management Assets Under Management All Assets Annual Asset Management Fee 0.25 of 1% (25 basis points) A minimum of $1 million in assets under management is required for this service. Chandler reserves the right to negotiate alternative minimum account size and advisory fees on a case-by-case basis. Chandler 6 | P a g e  will aggregate certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. LOCAL GOVERNMENT INVESTMENT POOLS FL SAFE and CalFIT pay a percentage of assets under management in accordance with the fees negotiated in the respective investment management agreements between Chandler, FL SAFE and CalFIT. Fees and services for a future local government investment pool client may be negotiated based on the extent and nature of advisory services that Chandler provides depending upon the specific arrangement provided to that client. Participants in either FL SAFE and CalFIT are delivered the Information Statement and other formation documents prior to investing. Please see the respective Information Statements for FL SAFE and CalFIT for further details. CONSULTING SERVICES FEES Chandler's Consulting Services fees will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. Chandler’s Consulting Services fees are calculated in one, or both, of two ways: 1. On a fixed fee basis, subject to the specific arrangement reached with the client; and/or 2. On an hourly basis, ranging up to $500.00 per hour. An estimate for the total hours is determined at the start of the advisory relationship. The length of time it will take to complete Consulting Services will depend on the scope and terms of the engagement. Fees are due and payable upon completion of the Consulting Service or on an agreed upon payment schedule. A retainer may be requested upon completion of Chandler's fact-finding session with the client; however, advance payment will never exceed $1,200 for work that will not be completed within six months. There is no minimum fee for Chandler’s Consulting Services. REPORTING SERVICES FEES For clients who elect to receive reporting services, Chandler generally charges a separate reporting fee with respect to non-managed assets included in such reports. The reporting fee is negotiable; however, Chandler’s standard proposal is an annual fee of one basis point (0.01%) of the value of all non-managed assets for which reporting is provided. No reporting fee is charged on local government investment pools directly managed by Chandler. Chandler’s annual reporting fee is billed monthly or in some instances quarterly, in arrears, and is calculated based on the average market value of a client's reporting account(s) for the billing period, unless indicated otherwise in the client agreement. Because reporting services cover accounts not managed by Chandler, asset values are generally based on information provided by custodians, clients, or other third-party sources and are not independently verified by Chandler. Clients should note that reporting service fees are in addition to any investment management fees charged on assets managed directly by Chandler, as well as any fees charged by custodians, third-party managers, or other service providers. ESG REPORTING SERVICES FEES For clients who elect to receive ESG Reporting Services, Chandler generally charges a separate reporting fee for such reports. The reporting fee is negotiable; however, Chandler’s standard proposal is an annual fee of one basis point (0.01%) of the value of all assets for which reporting is provided. Fees for ESG 7 | P a g e  Reporting Services are typically calculated and billed monthly in arrears, based on the asset values as of the last day of the prior month, unless otherwise agreed. GENERAL FEE INFORMATION Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to Chandler's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our firm's minimum account requirements and advisory fees differ among clients. Advisory Fees in General: Clients should note that similar advisory services may or may not be available from other registered investment advisers for similar or lower fees. Chandler’s clients are not required to pay any start-up or closing fees; there are no penalty fees. Termination of the Advisory Relationship: A client agreement between a client and Chandler may be canceled at any time, by either party, for any reason upon receipt of written notice. As disclosed in Item 5D below, certain fees may be paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded to the client. In calculating a client’s reimbursement of fees, we will pro rate to the effective date of termination on the basis of actual days elapsed. Fee Calculation: Chandler’s annual advisory fee is billed monthly or in some instances quarterly, in arrears, and is calculated based on the average market value of a client's account for the billing period, including accrued interest unless indicated otherwise in the client agreement. Cash and cash equivalent balances are included in the total market value calculation unless noted otherwise in the client agreement. We will value securities or investments in the portfolio in a manner determined in good faith to reflect fair market value. Chandler uses an independent third-party pricing source to value client securities. Limited Negotiability of Advisory Fees: Although Chandler has established the aforementioned fee schedules, we retain the discretion to negotiate alternative fees on a case-by-case basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These include the complexity of the client, the assets to be placed under management, the anticipated future additional assets, the existence of any related accounts, portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the written agreement between Chandler and each client. We group certain related client accounts for the purposes of achieving the minimum account size requirements and determining the annual advisory fee. Chandler reserves the right to reduce or waive advisory fees for services provided to related persons of the firm and their immediate family members. Such rates are not available to all of Chandler’s advisory clients. ITEM 5B: FEE PAYMENT Generally, each client’s custodian debits Chandler’s advisory fees from the client’s account and pays such fee directly to us upon receipt of an invoice, unless otherwise arranged by the client. Clients entering into written agreements with Chandler have discretion over whether or not Chandler may directly debit fees from the client’s account. Clients who do not permit direct debiting will be invoiced directly with payment due upon receipt of the invoice. ITEM 5C: OTHER FEES AND EXPENSES AND VALUATION POLICY Mutual Fund Fees: All fees paid to Chandler for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. The fees and expenses charged by mutual funds and ETFs are described in each fund's prospectus. These fees will 8 | P a g e  generally include a management fee, other fund expenses, 12b-1 fees and possible distribution or redemption fees. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Importantly, clients should review both the fees charged by mutual funds and ETFs and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Chandler is not affiliated with any mutual funds or ETFs, does not share in the fees charged by mutual funds and ETFs, does not participate in the investment decisions regarding the portfolios of mutual funds and ETFs and is not liable regarding such investments. The fees and related expenses charged by mutual funds and ETFs can be found in the respective fund’s prospectus and statement of additional information, which should be read carefully before investing. Short Term Idle Cash Investment: Chandler can move some or all of the non-invested cash in a client’s account to a money market mutual fund that may generate an interest return. If the cash is invested through a mutual fund, there may be times when an affiliate of the client’s custodian may be the manager of such fund and would receive separate management fees from the mutual fund. Chandler is not affiliated with any such custodian, does not share in that fee, does not participate in the investment decisions of the mutual fund portfolio and is not liable regarding such investments. Custodian and Broker Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any transaction charges imposed by a broker-dealer that effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Brochure for additional information. From time to time, Chandler recommends a custodian to clients who do not have an existing custodial relationship established. Among others, Chandler generally recommends Union Bank, Bank of New York/Mellon, US Bank, Wells Fargo, Bank of America or Charles Schwab & Co. Some of these custodians offer special pricing for institutional clients of Chandler. Chandler does not receive any compensation from the custodians we refer to our clients. The rates offered will depend on the size of the assets or type of account. Clients retain full discretionary authority over the selection of the custodian to be used. Valuation Policy: For all publicly traded securities held in clients’ accounts, Chandler receives daily prices electronically from a third-party provider, which are reviewed internally monthly by designated investment personnel. When it is believed that the price provided is not correct or for times when the third party does not provide a price, Chandler will obtain pricing from a different third-party pricing source. This creates a conflict of interest since this practice could incentivize the designated investment personnel to select a pricing source that reflects a higher price per share for the security. To address this conflict, Chandler maintains detailed written policies and procedures regarding valuation of clients’ securities, which includes among other things, a list of approved third-party pricing vendors used by Chandler and reviews of price changes by the Co-Chief Investment Officers and Chief Compliance Officer. ITEM 5D: PREPAID FEES Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. 9 | P a g e  ITEM 5E: COMPENSATION FOR THE SALE OF SECURITIES OR INVESTMENT PRODUCTS As discussed further in Item 10, Chandler, through common ownership and control, is affiliated with a registered broker-dealer which acts as marketing and distribution agent to certain investment pools to which Chandler also acts as investment adviser. However, Chandler is not affiliated with any broker-dealers or mutual fund companies which offer securities to the general public, and therefore we do not receive any compensation for the purchase or sale of securities or investment products used in client accounts, outside of those pools discussed here and in Item 10. 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE ITEM MANAGEMENT Chandler does not charge performance-based fees (i.e., fees calculated based on a share of capital gains on or capital appreciation of the client’s assets or any portion of the client’s assets). Consequently, we do not engage in side-by-side management of accounts that are charged a performance- based fee with accounts that are charged another type of fee (such as assets under management). ITEM 7: TYPES OF CLIENTS Chandler provides advisory services to the following types of clients: • State, local or other municipal government entities • Local Government Investment Pools (“LGIPs”) • Healthcare institutions • Higher education institutions • Charitable organizations • Pension and profit-sharing plans (other than plan participants) • Corporations or other business entities not listed above • Retirement Accounts As disclosed above in Item 5A of this Brochure, we have established certain initial minimum account asset requirements to maintain an account based on the nature of the service(s) being provided. For a more detailed understanding of those requirements, please review the disclosures provided in each applicable service. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ITEM 8A: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS METHODS OF ANALYSIS Chandler uses all or any combination of the following methods of analysis in formulating our investment advice and/or managing client assets: 10 | P a g e  • Fundamental Analysis. We attempt to measure the intrinsic value of a security or a market sector by looking at broad economic and financial factors (including the overall economy, industry conditions and the market’s valuation of the security or market sector) to identify securities or market sectors that we believe are fairly valued or undervalued. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the security. • Technical Analysis. We analyze past market movements and may occasionally apply that analysis to choose the price at which we wish to purchase or sell a given security. While we may seek a specific price for a security, technical analysis is never the main determinant of our purchase or sell process. A risk in using technical analysis is that the methods or models we use may not result in the best price of a given day. • Quantitative Analysis. We use a proprietary quantitative model (Horizon Analysis Model) that utilizes mathematical analysis to estimate the impact of interest rate changes on individual securities and portfolios of securities. The results of our quantitative analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. • Qualitative Analysis. We use qualitative analysis to evaluate individual securities, focusing on other non-quantifiable factors, such as quality of management, not readily subject to measurement and incorporate that analysis into our security selection process. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. • Asset Allocation. We generally focus on identifying an appropriate allocation of securities, maturities, market sectors and yield curve positioning suitable for the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the allocation will change over time due to market movements in the various sectors, which, if not corrected, may no longer be appropriate for the client’s goals. • Mutual Fund and/or ETF Analysis. In selecting mutual funds and ETFs for Multi Asset Class portfolios, we look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF to determine if there is significant overlap in the underlying investments held in other fund(s) in the client’s portfolio. We monitor the funds and ETFs to determine if they continue to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, potentially increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell as well as other purchased or publicly available sources of information about these securities are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. 11 | P a g e  FIXED INCOME PORTFOLIO MANAGEMENT INVESTMENT STRATEGIES We believe that a conservative, risk-controlled approach to fixed income management will provide both steady incremental outperformance and low relative volatility. • The disciplined process we employ in an effort to realize this philosophy is generally grounded in four key decisions: • Constraint of portfolio duration within a narrow range relative to the benchmark to limit exposure to market risk • Strategic allocations to key sectors to add value relative to the benchmark • Active management of term structure to add value in different yield curve environments • Security selection based on rigorous credit and relative value analysis and broad diversification of non-government issuers Within our fixed income strategy, we use the following sub-strategies in managing client accounts, provided that such sub-strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: • Duration Constraints. We adhere to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may underperform a neutral duration portfolio as bond prices move up or down. • Sector Allocation. We allocate client assets to various sectors of the fixed income market, including US Treasury obligations, federal agency securities, corporate notes, mortgage-backed securities and others based on our quantitative and qualitative analysis in order to manage client exposure to a given sector and to provide exposure to sectors we believe have good value. The risk of sector allocation is that clients may underperform depending on the allocation to any particular sector as those prices rise or fall. • Security Selection. A proprietary credit evaluation process drives our security selection process. The system uses both internally and externally generated credit research to evaluate securities we are considering for purchase. Based on research we conduct internally, our Credit Committee selects securities for our Approved List. The ultimate decision to purchase or sell a security is based on the firm’s evaluation of the current price for the security. The risk of security selection is that the methods of analysis employed will not provide accurate measurement of the risk association with each individual security. • Long-term purchases. We purchase securities with the idea of holding them in the client's account for a year or longer. Typically, we employ this sub-strategy when: o We believe the securities to be well valued, and/or o We want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our analysis is incorrect, a security may decline sharply in value before we make the decision to sell. MULTI ASSET CLASS PORTFOLIO MANAGEMENT INVESTMENT STRATEGIES We invest in Multi Asset Class portfolios for clients with certain objectives and risk tolerances. This strategy begins with assumptions that the firm develops about the expected long-term performance of various asset 12 | P a g e  classes including domestic and foreign stocks and bonds, real estate, commodities, cash and others. Based on the expected returns and risk characteristics of these asset classes, we prepare an asset allocation suitable for the individual client’s objectives and risk tolerances. The investment vehicles that we currently employ for this strategy are mutual funds or exchange-traded funds (“ETFs”) that are designed to track market returns and volatilities. The mutual funds or ETFs will be selected based on any or all of the following criteria: the fund's performance history, the industry sector in which the fund invests, the fund manager’s track record, the fund's investment objectives, the fund's management style and philosophy and the fund's management fee structure. Portfolio weighting between funds and market sectors will be determined by each client's individual needs and circumstances. Once the client’s portfolio is in place, we rebalance it each quarter to the client’s target allocation. On an annual basis, at a minimum, we review the costs and performance of our selected investment vehicles to ensure the funds or ETFs are performing as we expect. The risks of this strategy include (1) that our analysis of long-term return expectations will not be correct; (2) that the portfolios will not be properly rebalanced; and (3) that the investment vehicles we employ will not track market returns and volatility as we expect. Detailed information on the risks associated with the investments made by the mutual funds or ETFs will be outlined in each fund’s prospectus. LOCAL GOVERNMENT INVESTMENT POOL INVESTMENT STRATEGIES All investments involve risk and investing in the Local Government Investment Pools (“LGIPs”) is no exception. Set forth below are the principal risk factors of the LGIPs. Please refer to the respective Information Statements for FL SAFE and CalFIT for more information. • Concentration Risk: Any fund that concentrates in a particular segment of the market will generally be more volatile than a fund that invests more broadly. Any market price movements, regulatory or technological changes, or economic conditions affecting banks or financial institutions may have a significant impact on an LGIP’s performance. • Counterparty Risk: Each of the LGIPs is exposed to the risk that third parties that owe it money, securities or other assets will not perform their obligations. These parties may default on their obligations due to bankruptcy, lack of liquidity, operational failure or other reasons. • Credit Risk: The issuer of a debt security may fail to pay interest or principal when due, and changes • • in credit quality may reduce the value of debt securities or reduce the LGIP’s returns. Interest Rate Risk: Rising interest rates could cause the value of the LGIP’s investments, and therefore its share price as well, to decline. Conversely, any decline in interest rates is likely to cause the LGIP’s yield to decline, and during periods of unusually low interest rates, the LGIP’s yield may approach zero. While the LGIP’s service providers may voluntarily agree to waive a portion of their fees to support a positive yield during periods of low interest rates, there is no assurance they will do so. For floating-rate obligations and variable-rate obligations, because the interest these securities pay is adjustable, there are market environments where they may have a beneficial or detrimental impact to the yield of the LGIPs relative to fixed rate securities issued by similar issuers and terms to maturity. Issuer Risk: The value of a security may decline because of adverse events or circumstances that directly relate to conditions at the issuer or any entity providing it credit or liquidity support. 13 | P a g e  • Lack of Governmental Insurance or Guarantee: An investment in the LGIPs is not a bank deposit. Investments in LGIPs are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. • Liquidity Risk: LGIPs could experience significant net redemptions of its shares at a time when it was unable to find willing buyers for its portfolio securities or could only sell its portfolio securities at a material loss. In addition, with respect to a Variable NAV pool, there are restrictions on a participant’s ability to withdraw funds from such pool. • Management Risk: LGIPs are subject to management risk, which is the risk that poor security selection by Chandler could cause an LGIP to underperform relevant benchmarks or other funds with a similar investment objective. There is no guarantee of the LGIP’s performance or that the LGIP will meet their objective. The market value of your investment may decline and you may suffer investment loss. • Market Risk: The market price of securities owned by an LGIP may rapidly or unpredictably decline due to factors affecting securities markets generally or particular industries. • Ratings Risk: There is no guarantee that an LGIP will achieve or maintain any particular rating. • Regulatory Risk: Changes in government regulations may adversely affect the value of a security. An insufficiently regulated industry or market might also permit inappropriate practices that adversely affect an investment. • Redemption Risk: LGIPs may experience periods of heavy redemptions that could cause the applicable fund to liquidate its assets at inopportune times or at a loss or depressed value, particularly during periods of declining or illiquid markets. Redemptions by a few large participants may have a significant adverse effect on the ability to maintain a stable $1.00 share price or the net asset value of the LGIPs, as applicable. Further, under circumstances described in the “How to Redeem Shares in the Funds” of the Information Statement, redemptions from the LGIPs may be temporarily suspended. • Repurchase Agreement Risk: A repurchase agreement involves the purchase of a security coupled with an agreement by the seller to repurchase the security at a specified date and price. While repurchase agreements are intended to provide safety and liquidity, participants in LGIPs should understand that these transactions are not risk-free and may expose the LGIP to losses under certain circumstances. While these agreements are generally considered low risk and provide short-term liquidity, they carry the following risks: • Counterparty Default Risk: If the party that sells the security fails to repurchase it as agreed, the LGIP could experience delays in recovering its cash or suffer a loss if the market value of the underlying security declines. • Collateral Risk: Although repurchase agreements are typically collateralized, the value of the collateral may decrease or prove insufficient to cover the seller’s obligation, particularly during periods of market stress. • Liquidity Risk: In stressed market conditions, it may be difficult to sell the collateral securities quickly without a loss in value, potentially limiting the LGIP’s ability to meet redemption requests. • Operational Risk: Repurchase agreements rely on proper settlement, custody, and monitoring of collateral. Failures in these operational processes could increase the risk of loss. • Stable NAV Risk: Although an LGIP may seek to maintain the value of a participant’s investment at $1.00 per share (a Stable NAV pool), the share price is not guaranteed, and if it falls below $1.00 14 | P a g e  and a participant could lose money. The share price could fall below $1.00 as a result of the actions of one or more large participants in an LGIP. The credit quality of an LGIP can change rapidly in certain markets, and the default of a single holding could cause an LGIP’s share price to fall below $1.00, as could periods of high redemption pressures and/or illiquid markets. • Variable NAV Risk: In contrast, the net asset value of a Variable NAV pool will fluctuate as the market value of the securities in the portfolio changes over time, and the net asset value of a participant’s investment could decline below the amount originally invested by the participant. A participant that cannot bear this risk should not invest in the Variable NAV pool. • Temporary Suspension of Redemptions: Under certain circumstances, redemptions from the LGIPs may be temporarily suspended. • U.S. Government Obligations Risk: U.S. government obligations may be adversely impacted by changes in interest rates. For U.S. government obligations that are not backed by the full faith and credit of the U.S. government, there can be no assurance that the U.S. government will provide financial support when it is not obligated to do so. ITEM 8B: MATERIAL RISKS Risk of Loss: Securities investments are not guaranteed, and a client may lose money on their investments. We ask that each client work with us to help us understand their tolerance for risk. Investors should be aware that investment prices fluctuate as the securities are affected by economic and other factors. As a result, the value of your investment may increase or decrease. Bonds held to maturity will return the full par or face value amount to the bondholder at maturity (absent a default); however, those sold prior to maturity are subject to gain or loss depending on the market price at the time of sale. For risks specific to a particular method of analysis or investment strategy, please see Item 8A above. For risks specific to a particular type of security, please see Item 8C below. ITEM 8C: RISKS ASSOCIATED WITH PARTICULAR TYPES OF SECURITIES USED RISKS ASSOCIATED WITH FIXED INCOME SECURITIES Chandler specializes in investment grade fixed income portfolio management. Despite the generally conservative nature of many fixed income investments, there are a variety of risks associated with fixed income investing. Fixed income securities represent monies lent by investors to corporate and government institutions. Risks vary according to the type of fixed income investment purchased along with the general level of interest rates in the economy. The risks commonly associated with fixed income securities are: • • Market Risk: The price of the security may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. Interest Rate Risk: The risk that the value of an interest-bearing investment will change due to changes in the general level of interest rates in the market. The market value of a bond fluctuates inversely to the change in interest rates; that is, as interest rates rise, bond prices fall and vice versa. Interest rate risk is commonly measured by a bond’s duration, the greater a bond’s duration, the greater the impact on price of a change in interest rates. Investors may incur a gain or loss from bonds sold prior to the final maturity date. 15 | P a g e  • Credit Risk: The risk that principal and/or interest on a fixed income investment will not be paid in a timely manner or in full due to changes in the financial condition of the issuer. Generally, the higher the perceived credit risk, the higher the rate of interest investors will receive on their investment. Many bonds are rated by a third party Nationally Recognized Statistical Rating Organization (NRSRO), for example, Moody’s Investor Services or Standard & Poor’s Inc. While ratings may assist investors to determine the creditworthiness of the issuer, they are not a guarantee of performance. • Reinvestment Risk: The risk that interest and principal payments from a bond will be reinvested at a lower yield than that received on the original bond. During periods of declining interest rates, bond payments may be invested at lower rates; during periods of rising rates, bond payments may be invested at higher rates. • Call Risk: The risk that a bond will be called by its issuer. A callable bond has a provision which allows the issuer to purchase the bond back from the bondholders at a predetermined price. Generally, issuers call bonds when prevailing rates are lower than the cost of the outstanding bond. Call provisions allow an issuer to retire high-rate bonds on a predefined call schedule. • Prepayment Risk: Some types of bonds are subject to prepayment risk. Similar to call risk, prepayment risk is the risk that the issuer of a security will repay principal prior to the bond’s maturity date, thereby changing the expected payment schedule of the bonds. Prepayment risk is particularly prevalent in the mortgage-backed bond market, where a decline in interest rates can trigger loan holders to pre-pay their mortgages. When investors in a bond comprised of the underlying pool of mortgages receives his or her principal back sooner than expected, they may be forced to reinvest at prevailing, lower rates. • • Liquidity Risk: The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in a wide bid-ask spread or large price movements. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Opportunity Cost Risk: The risk that an investor may forego profits or returns from other investments. RISKS ASSOCIATED WITH MUTUAL FUNDS AND EXCHANGE TRADED FUNDS As discussed in further detail in Item 4B above, Chandler also offers a Multi Asset Class strategy to clients seeking to attain balanced returns. This strategy provides exposure to various equity, fixed income and other asset classes through investments in indexed or actively managed mutual funds and exchange traded funds (“ETFs”). Chandler is not affiliated with any such mutual fund or ETF company, does not share in any fees charged by a mutual fund or ETF and does not participate in any investment decisions relating to the management of a mutual fund or ETF portfolio. Mutual Funds A mutual fund is a company that pools money from many investors and invests the money in different securities or assets based on the investment strategy or goals of the particular fund. Each share of a mutual fund represents an investor’s proportionate ownership of the fund’s holdings and the income those holdings generate. The risks most commonly associated with mutual funds are: 16 | P a g e  • Market Volatility: Investment returns will fluctuate and are subject to market volatility, so that a client’s shares, when redeemed or sold, may be worth more or less than their original cost. Past performance is no guarantee of future results. • Tracking Error for Index Funds: Index mutual funds seek to track the returns of a market benchmark such as the S&P 500 index, by holding the same securities or a representative sample. A risk of using index mutual funds is that the fund may not be able to track its benchmark closely creating the potential for lower returns than the benchmark. • Lack of Control/Transparency: Clients typically are not given the exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades. • • Price Uncertainty: With an individual stock, a client can obtain real-time pricing information with relative ease by either checking financial websites or by calling a broker. With a mutual fund, the price at which a client purchases or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until many hours after a client has placed their order. Mutual funds generally calculate their NAV at least once per business day. International Risk: Chandler invests in Mutual Funds offered by US based fund companies that invest in non-US companies and markets, which entail additional risks. Non-US markets may be more volatile due to a variety of factors including, less liquidity, transparency and oversight of companies or assets. Values of non-US investments may fluctuate due to changes in currency exchange rates. Non-US companies are also subject to risks that come with political and economic stability that may affect their respective countries. These risks may be greater in emerging market countries. Exchange-Traded Funds (ETFs) ETFs are investment funds that trade on stock exchanges much like stocks and will fluctuate in market value. ETFs also may trade at prices above or below the ETFs net asset value. Brokerage commissions and ETF expenses will reduce returns. Additionally, frequent trading of ETFs could significantly increase commissions and other costs such that they may offset any savings from low fees or costs. Equity based ETFs are subject to risks similar to those of stocks and fixed income ETFs are subject to risks similar to those of bonds. The risks most commonly associated with ETF securities are: • Market Volatility: Investment returns will fluctuate and are subject to market volatility, so that a client’s shares, when redeemed or sold, may be worth more or less than their original cost. Past performance is no guarantee of future results. • Tracking Error for Index ETFs: Index ETFs seek to track the returns of a market benchmark such as S&P 500 index, by holding the same securities or a representative sample. A risk of using index ETFs is that the fund may not be able to track its benchmark closely creating the potential for lower returns than the benchmark. • Lack of Control/Transparency: Clients typically are not given the exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades. • Liquidity Risk: The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in a wide bid-ask spread or large price movements. 17 | P a g e  • International Risk: Chandler invests in ETFs offered by U.S. based fund companies that invest in non-U.S. companies and markets, which entail additional risks. Non-U.S. markets may be more volatile due to a variety of factors including, less liquidity, transparency and oversight of companies and assets. Values of non-U.S. investments may fluctuate due to changes in currency exchange rates. Non-U.S. companies are also subject to risks that come with political and economic stability that may affect their respective countries. These risks may be greater in emerging market countries. Chandler does not represent, guarantee or imply that the services or methods of analysis employed by us can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines ITEM 9 – DISCIPLINARY INFORMATION We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Neither our firm nor our Management Persons have any reportable disciplinary events to disclose. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Chandler serves in an administrative capacity for FL SAFE and CalFIT for which Chandler also serves as the Investment Adviser (please see Items 4 and 5 for further details). In providing these services, Chandler, receives a percentage of the average daily net assets of the FL SAFE and CalFIT portfolios. These fees vary based on the services requested by FL SAFE or CalFIT, and the amount of the assets under administration. Participants in FL SAFE or CalFIT are delivered the Information Statement and formation documents prior to investing. Please see the Information Statement for your respective LGIP more details. Chandler Distribution Services, LLC Through its parent company, Chandler Investor Services, Inc, Chandler is under common ownership and control with Chandler Distribution Services, LLC ("Chandler Distribution"), a broker-dealer registered with the U.S. Securities and Exchange Commission (“SEC”), the Financial Industry Regulatory Authority (“FINRA”), the Securities Investor Protection Corporation (“SIPC”), the Municipal Securities Rulemaking Board (“MSRB”) and certain states. Chandler Distribution provides marketing and distribution services to certain interests of local government investment pools (“LGIP”) to which Chandler also acts as investment adviser. Potential Conflicts of Interest Due to this affiliation, conflicts of interest may arise, including, but not limited to: 1. Chandler may recommend investing in LGIPs distributed by Chandler Distribution, which could result in indirect compensation for the affiliated entity. 2. Employees of Chandler may also be registered representatives of Chandler Distribution, creating an incentive to recommend products or services that provide additional compensation. 3. The placement of LGIP interests by Chandler Distribution benefits Chandler because Chandler acts as investment adviser to these same LGIPS, thus resulting in Chandler receiving compensation for its advisory services to those LGIPs. 18 | P a g e  Chandler addresses these conflicts as follows: • All recommendations are made in the best interests of clients and are based on their individual investment goals and financial circumstances. • Chandler maintains policies and procedures, including disclosure of conflicts and employee training, to ensure recommendations are unbiased and fully compliant with applicable fiduciary standards. • Clients are encouraged to review all recommendations and ask questions to ensure they understand potential conflicts and the rationale behind the advice provided. If you have questions about Chandler’s relationship with Chandler Distribution, please contact us at us at 858-546-3737 or compliance@chandlerasset.com. ITEM 11 – CODE OF ETHICS, PARTICIPTION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ITEM 11A: CODE OF ETHICS Our firm maintains a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Chandler and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement), an initial public offering and certain other securities. Our Code also provides for oversight, enforcement and recordkeeping provisions. Chandler's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any access to non-public information, all employees are periodically reminded that such information may not be used in a personal or professional capacity. Our Code of Ethics is distributed to all supervised persons of Chandler whenever revisions are made or no less frequently than annually, at which time all employees are required to provide a written acknowledgement and attestation of their intent to abide by Chandler’s Code provisions. Additionally, firm- wide annual training regarding Chandler’s Code of Ethics is provided by Compliance. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to compliance@chandlerasset.com, or by calling us at 858-546-3737. ITEM 11B: PRINCIPAL TRADING AND AGENCY CROSS TRADING Chandler and individuals associated with our firm are prohibited from engaging in principal transactions. Chandler and individuals associated with our firm are prohibited from engaging in agency cross transactions. 19 | P a g e  ITEM 11C: PERSONAL TRADING Chandler and/or individuals associated with our firm can from time to time, buy or sell for their personal accounts, securities identical to or different from those recommended to our clients. In addition, any related person(s) could potentially have an interest or position in a security(ies) which may also be recommended to a client. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients, and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. It is also designed to help prevent employees from benefiting from transactions placed on behalf of advisory clients. For additional information on how we address the conflicts of interest that arise in connection with personal trading, please see Item 11D below. ITEM 11D: PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS From time to time, Chandler will aggregate trades for our self or our employees with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. In instances where there is a partial fill of a particular aggregated order, we will allocate all purchases pro-rata, with each account paying the average price. Our employee accounts will be excluded in such a pro-rata allocation. Because the situations outlined above represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. 3. No principal or employee may benefit from transactions placed on behalf of advisory accounts. 4. Our firm requires prior approval for any IPO, private placement investments and certain other securities by related persons of the firm. 5. We maintain a list of all reportable securities holdings for our firm, and anyone associated with this advisory practice that has access to advisory recommendations ("access person"). These holdings are reviewed on a regular basis by our firm's Chief Compliance Officer or designee. 6. We have established procedures for the maintenance of all required books and records. 7. Clients may decline to implement any advice rendered, except in situations where our firm is granted discretionary authority. 8. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 9. We require delivery and acknowledgement of the Code of Ethics by each supervised person (as defined by the Code) of our firm. 10. We have established policies requiring the reporting of Code of Ethics violations to our senior management. 20 | P a g e  11. Any individual who violates any of the above restrictions may be subject to sanctions, which may include termination of employment. ITEM 12 – BROKERAGE PRACTICES ITEM 12A: BROKER-DEALER SELECTION, COMPENSATION & TRADE AGGREGATION FIXED INCOME & MULTI ASSET CLASS PORTFOLIO MANAGEMENT Chandler requires discretionary clients to provide us with written authority to determine broker-dealer selection and commission costs that will be charged to these clients for transactions placed in their account(s). Broker-dealers are selected by Chandler based on best execution, a combination of most favorable price and the quality of execution. In selecting a broker to execute a transaction for a client, Chandler considers a variety of other factors, including (but not limited to) the following: • The broker-dealer's capital depth; • The broker-dealer's market access; • The nature of the security or instrument being traded; • The size and type of transaction; • The nature and character of the markets for the security or instrument to be purchased or sold; • The desired timing of the transaction; • The execution, clearance and settlement capabilities of the broker-dealer selected, and others considered; • The reputation and perceived soundness of the broker-dealer and others considered; • Chandler's knowledge of any actual or apparent operational problems with the broker-dealer; and • The reasonableness of the commission for specific transactions. While Chandler generally seeks competitive commission rates and dealer spreads, it may not necessarily pay the lowest commission. Transactions may involve specialized services on the part of the broker-dealer and thereby justify higher commissions than would be the case with other transactions requiring more routine services. Regarding commission rates paid, Chandler’s fixed income transactions are generally executed by the broker-dealer on a net basis, which means the execution costs (e.g., commissions) are included in the purchase or sale price of the security. Equity and ETF transactions will be charged commissions. ITEM 12A.1: SOFT DOLLAR ARRANGEMENTS AND OTHER BENEFITS Chandler’s soft dollar policy prohibits us from entering into third party soft dollar arrangements. ITEM 12A.2: RESEARCH FROM APPROVED BROKERS When placing trades with brokers, there are times when Chandler places certain trades with a third party approved broker that is providing brokerage services and proprietary research to us (“Approved Broker”). Brokerage and research services provided by Approved Brokers can include, among other things, effecting securities transactions, performing services incidental thereto (such as clearance, settlement and custody) and providing proprietary research. The research can pertain to the economy, industries, sectors of securities, individual companies, statistical information, political and/or developments, credit, and risk 21 | P a g e  measurement and/or performance analysis. In selecting a broker for trade placement, Chandler can place transactions with Approved Brokers that charge commissions, transaction costs or mark-ups that are more than that which another broker might have charged for effecting the same transaction, in recognition of the value of the brokerage services and research they are providing. In some cases, the research provided by Approved Brokers is not utilized by Chandler and in other cases, it can be used in servicing any or all of our clients. In other words, there can be certain client accounts that benefit from the research, which did not make the payment of commissions, transaction costs or mark-ups to the Approved Broker providing the services. Importantly, the receipt of brokerage services and proprietary research from any Approved Broker executing transactions for our clients will not result in a reduction of our customary and normal research activities. Also, the receipt of this type of research can be deemed to be the receipt of an economic benefit by us, and although customary, creates a conflict of interest between Chandler and our clients. Therefore, we believe it is necessary to provide these disclosures. In addition, we only place our clients’ trades where we believe best execution will be obtained, taking into consideration all factors surrounding the transaction and not just research received. ITEM 12A.3: BROKERAGE FOR CLIENT REFERRALS Chandler does not direct brokerage in exchange for client referrals. ITEM 12A.4: DIRECTED BROKERAGE Chandler’s policy and practice is not to accept advisory clients’ instructions for directing client’s brokerage transactions; however, from time-to-time, Chandler accepts written direction from a client regarding the use of a particular broker-dealer to execute some or all transactions for the client’s account(s). In these circumstances, clients should understand that: (1) we do not negotiate specific brokerage commission rates with the broker on client’s behalf, or may not seek better execution services or prices from other broker/dealers and, as a result, the client may pay higher commissions and/or receive less favorable net prices on transactions for their account than might otherwise be the case; (2) transactions for that account generally will be effected independently unless we decide to purchase or sell the same security for several clients at approximately the same time (block trade), in which case we may be able to include such client’s transaction with that of other clients for execution if at the same broker; and (3) conflicts may arise between the client’s interest in receiving best execution with respect to transactions effected for the account and Chandler’s interest in receiving future client referrals from that broker. Therefore, prior to directing us to use a specific broker-dealer, clients should consider whether, under that restriction, execution, clearance and settlement capabilities, commission expenses and whatever amount is allocated to custodian fees, if applicable, would be comparable to those otherwise obtainable. Clients should understand that they might not obtain commissions rates as low as might otherwise be obtain if we had discretion to select other broker- dealers. ITEM 12B: AGGREGATING CLIENT TRADES Order aggregation is the process of adding together or “blocking” orders to purchase and sell the same security as one large order. Chandler will aggregate or “block” trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts and in some cases, employees, and other proprietary accounts so long as transaction costs are shared equally and on a pro-rata (or other fair and reasonable) basis between all accounts included in any such block. Block trading may allow us to execute trades in a timelier, more equitable manner at a better overall price. 22 | P a g e  Chandler will aggregate trades for itself or for its associated persons with client trades, provided that the following conditions are met: 1. Chandler's policies for the aggregation of transactions shall be fully disclosed in this Form ADV Part 2A, separately to Chandler's existing clients (if any) and to the broker-dealer(s) through which such transactions will be placed; 2. We will not aggregate transactions unless aggregation is consistent with our duty to seek best execution and the terms of Chandler’s investment advisory agreement with each client for which trades are being aggregated; 3. No participating account will be favored over any other account; each account that participates in an aggregated order will participate at the average price for all the aggregated order, with transaction costs shared pro-rata, when applicable, on each account’s participation in the transaction; 4. Chandler will enter aggregated orders into our Order Management System (“OMS”), specifying the participating accounts and how we intend to allocate the order among those accounts; 5. If the aggregated order is filled in its entirety, it will be allocated among participating accounts in accordance with the allocations entered into the OMS. If the order is partially filled, it will be allocated pro-rata based on the allocations entered into the OMS; 6. If the security is purchased from multiple dealers at different prices and is to be allocated among multiple accounts, it will be allocated using a weighted average method; 7. Allocations for an aggregated order should constitute no less than 0.50 of 1% (50 basis points) of a selected portfolio. If a proposed allocation would amount to less than 0.50 of 1% (50 basis points) of the selected portfolio, it may be allocated to a more appropriate account different from that specified in the OMS as long as all client accounts receive fair and equitable treatment and the reason for the different allocation is explained in a manner consistent with the procedures listed in number 8 herein; 8. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the OMS if all client accounts receive fair and equitable treatment and the reason for the different allocation is explained in writing and is approved in writing by appropriate supervisory personnel no later than one hour after the opening of the markets on the trading day following the day the order was executed; 9. Chandler will receive no additional compensation of any kind as a result of the proposed aggregation; 10. Individual investment advice and treatment will be accorded to each advisory client; 11. Chandler’s books and records will separately reflect, for each client account, the orders of which are aggregated, the securities held by and bought and sold for that account; and 12. Funds and securities for aggregated orders are clearly identified on Chandler's records and to the broker-dealers or other intermediaries handling the transactions by the appropriate account numbers for each participating client. There are times when Chandler does not aggregate trades when we have an opportunity to do so. Portfolio managers choose not to aggregate trades in the following situations: • Non-discretionary clients: An advisory client electing not to grant investment discretionary authority to Chandler is advised that trades done in his/her account may be executed after trades effected in discretionary accounts due to the additional time involved in obtaining the required client approval prior to executing any trade in such non-discretionary client accounts. Consequently, we may not be able to aggregate these trades with other discretionary trades which 23 | P a g e  may result in a difference in the price per share/bond of a given security and the commission rates paid. • Client direction: While rare, an advisory client may choose not to have their trades aggregated or may have cash flow needs that prevent Chandler from aggregating a trade with other pending orders. Consequently, we may not be able to aggregate these client trades with other client trades which may result in a difference in the price per share/bond of a given security and the commission rates paid. • Portfolio Manager’s discretion: Portfolio managers may choose to trade certain strategies at the same time while waiting to trade others. The timing of the trades and determination of which strategy to trade is dependent on market conditions. Additionally, not all portfolio managers will trade their client accounts at the same time and there may be timing differences for trades executed by different portfolio managers. Accordingly, we may not be able to aggregate all trades executed independently by our different portfolio managers, which may result in a difference in the price per share/bond of a given security and the commission rates paid. ITEM 13 – ACCOUNTS REVIEWS ITEM 13A: PERIODIC ACCOUNT REVIEWS PORTFOLIO MANAGEMENT The underlying securities within these types of accounts are continually monitored and reviewed daily in our Order Management and Portfolio Compliance System (“OMS”) in the context of each account's stated investment objectives and guidelines. Additional reviews may be triggered by material changes in variables such as the client's individual circumstances, liquidity requirements, credit analysis or the market, political or economic environment. These accounts are reviewed by our Co-Chief Investment Officers, Portfolio Managers and our Compliance Department. CONSULTING SERVICES While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Consulting Services clients unless otherwise contracted for. Such reviews will be conducted by the client's account representative. ITEM 13B: OTHER REVIEWS Chandler reviews accounts on a periodic basis as described above in Item 13A of this brochure. ITEM 13C: REPORTING FIXED INCOME, MULTI ASSET CLASS PORTFOLIO MANAGEMENT AND LOCAL GOVERNMENT INVESTMENT POOLS In addition to the monthly account statements that clients receive from their custodian and confirmations of transactions that they receive from the executing broker-dealer, we provide written monthly reports summarizing account performance, balances and holdings, transactions, income earned and cash flow expected for the next 365 days. CONSULTING SERVICES These client accounts will receive written reports as contracted for at the inception of the advisory engagement. 24 | P a g e  ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ITEM 14A: OTHER COMPENSATION Chandler does not receive any economic benefits from any person or entity other than its clients in connection with the provision of investment advice. Chandler receives compensation solely for the investment advisory services it provides to clients, as described in this Form ADV. No other compensation, including sales awards, bonuses, or other economic benefits, is received from third parties. ITEM 14B: CLIENT REFERRALS Chandler’s policy and practice is not to enter into arrangements to pay referral fees to independent persons or firms ("Solicitors") for introducing clients to us. Compensation paid to certain related persons of Chandler takes into consideration an overall assessment of predetermined objectives in addition to other defined criteria. Notably, this firm practice does not impact the advisory fees paid to Chandler by any client. ITEM 15 – CUSTODY Chandler does not take custody or possession of the funds or securities that a client has placed under our management. Each client shall appoint a Qualified Custodian (“custodian”) to take and have possession of their assets. The fees expressed in the “Fees and Compensation” section (Item 5A) of this Brochure do not include fees a client will incur for custodial services. From time to time, Chandler recommends a custodian to clients who do not have an existing custodian relationship established. Among others, Chandler generally recommends (in alphabetical order) Bank of America, Bank of New York/Mellon, Charles Schwab & Co. or US Bank. Some of the above-mentioned custodians offer special pricing for institutional or municipal clients of Chandler. Chandler does not receive any compensation or referrals from the custodians we refer our clients to. The rates offered by the custodian can be based on the size of the portfolio or type of account opened. Client retains full discretionary authority over the selection of the custodian to be used. Direct Debiting of Fees. Although Chandler does not take custody or possession of the funds or securities that a client has placed under its management, Chandler is deemed by the SEC to have custody of those accounts where fees are debited directly from the client’s custodian bank account. We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send the client a statement showing all transactions and holdings within the account during the reporting period, in addition to any advisory fees paid. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. In addition to the periodic statements that clients receive directly from their custodians, we also send account statements directly to our clients monthly. While Chandler makes every effort to provide accurate statements, we urge our clients to carefully compare the information provided on our statements to 25 | P a g e  statements provided by their custodian in order to ensure that all account transactions, holdings and values are correct and current. ITEM 16 – INVESTMENT DISCRETION Generally, clients hire us to provide discretionary asset management services; however, we do provide our services on a non-discretionary basis, if requested by a client. Our discretionary authority includes the ability to do the following without first obtaining approval from the client: • Determine the security to buy or sell; • Determine the amount of the security to buy or sell; and • Determine the price at which to buy or sell the security. Clients give us discretionary authority when they sign a discretionary client agreement with our firm and may limit this authority by giving us written instructions. Such limitations are typically outlined in a client’s investment policy statement and may include restrictions on maturity or ratings, issuer or sector concentration limitations, among others. Clients may also change/amend such limitations by once again providing us with written instructions. Chandler reserves the right to decline acceptance of any client account. ITEM 17 – VOTING CLIENT SECURITIES ITEM 17A: PROXY VOTING We vote proxies for the securities held in client accounts where the client has given us authorization to do so. All clients retain the right to vote their own proxies should they choose to do so. Clients can exercise this right by instructing us in writing to not vote proxies in their account and instructing their custodian to send proxies directly to their attention. We will vote proxies in the best interests of our clients and in accordance with our established policies and procedures. Our firm will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, a copy of any document created by us that was material to making a decision how to vote proxies and a copy of each written client request for information on how the adviser voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify the client of the conflict and retain an independent third party to cast a vote. Clients may obtain a copy of our complete proxy voting policies and procedures by contacting our Chief Compliance Officer, by telephone, email or in writing. Clients may request, in writing, information on how proxies for their shares were voted. If any client requests a copy of our complete proxy policies and procedures or how we voted proxies for their account(s), we will promptly provide such information to the client. We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. 26 | P a g e  With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor’s right to vote proxies. To direct us to vote a proxy in a particular manner, clients should contact our Chief Compliance Officer in writing by email or by mail. You can instruct us to vote proxies according to criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so-called "poison pill" defense against a possible takeover). You can also instruct us on how to cast your vote in a particular proxy contest by contacting our Chief Compliance Officer by mail at 9255 Towne Centre Drive, Suite 600, San Diego, CA 92121 or by email at compliance@chandlerasset.com. These requests must be made in writing. ITEM 17B: WHERE CLIENT RETAINS RIGHT TO VOTE PROXIES For accounts where we do not vote proxies, Chandler may provide investment advisory services relative to client investment assets. Clients maintain exclusive responsibility for: 1. Directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted; and 2. Making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets; and 3. Instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. We may provide clients with consulting assistance regarding proxy issues if they contact us with questions at our principal place of business. ITEM 18 – FINANCIAL INFORMATION ITEM 18A: FINANCIAL STATEMENT REQUIREMENT Under no circumstances do we require or solicit payment of fees in excess of $1200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. ITEM 18B: FINANCIAL CONDITION Chandler has no financial conditions to disclose that would impair its ability to meet contractual and fiduciary obligations to clients. ITEM 18C: BANKRUPTCY DISCLOSURE Chandler has never been the subject of a bankruptcy petition. 27 | P a g e