MCELHENNY SHEFFIELD CAPITAL MANAGEMENT, LLC

Item 1 Cover Page FIRM BROCHURE MCELHENNY SHEFFIELD CAPITAL MANAGEMENT, LLC 4701 W. Lovers Lane, Dallas, Texas 75209 (214) 922-9200 www.mscm.net This Form ADV Part 2 (“Brochure”) provides informa(cid:415)on about the qualifica(cid:415)ons and business prac(cid:415)ces of McElhenny Sheffield Capital Management, LLC. If you have any ques(cid:415)ons about the contents of this Brochure, please contact us at (214) 922-9200 or bruce@mscm.net. The informa(cid:415)on in this Brochure has not been approved or verified by the United States Securi(cid:415)es and Exchange Commission (“SEC”) or by any state securi(cid:415)es authority. Addi(cid:415)onal informa(cid:415)on about McElhenny Sheffield Capital Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. September 30, 2025  Item 2 Material Changes The following material changes have been made to this Brochure since the last update on August 21, 2025:  Item 4: Enhanced disclosure with respect to potential investment opportunities for Separately Managed Accounts.  Items 5 and 10: Enhanced disclosure with respect to management fees paid by clients investing in variable insurance vehicles.  Item 8: Enhanced disclosure with respect to investments in leveraged ETFs. The following material changes have been made to this Brochure since the last update on July 21, 2025:  Item 4: Enhanced disclosure to highlight the risks inherent with the Trend X strategy investing in leveraged ETFs and to clarify the high-risk tolerance required for Clients to consider such a strategy.  Item 8: Enhanced risk disclosures with respect to leveraged ETFs.  Item 10: Clarified that insurance advice provided to Clients by certain Supervised Persons, although not supervised by MSCM, will require prior approval by MSCM Compliance to determine that such activity is appropriate to be offered to a Client. The following material changes have been made to this Brochure since the last annual update on March 31, 2025:  Item 7: Enhanced disclosure to further clarify that Clients have Reserved Rights and therefore nothing in the IMA purports to waive or limit any Reserved Rights that Clients have under federal and state securities laws.  Item 15: Updated disclosures to clarify our reliance on the Custodians for valuations for portfolio positions and fee billing purposes. This Brochure will be delivered to Clients, as required. A copy of this Brochure, as well as MSCM’s Form CRS disclosure for retail Clients, is available for download from SEC’s website at www.adviserinfo.sec.gov. Page 2 of 28  Item 3 Table of Contents Item 1 Cover Page ................................................................................................................................................ 1 Item 2 Material Changes ...................................................................................................................................... 2 Item 3 Table of Contents ...................................................................................................................................... 3 Item 4 Advisory Business ..................................................................................................................................... 4 Item 5 Fees and Compensa(cid:415)on ........................................................................................................................... 7 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 ................................................................ 11 Item 9 Disciplinary Informa(cid:415)on ......................................................................................................................... 20 Item 10 Other Financial Industry Ac(cid:415)vi(cid:415)es and Affilia(cid:415)ons ................................................................................ 20 Item 11 Code of Ethics, Par(cid:415)cipa(cid:415)on or Interest in Client Transac(cid:415)ons and Personal Trading ........................... 21 Item 12 Brokerage Prac(cid:415)ces ................................................................................................................................ 22 Item 13 Review of Accounts ................................................................................................................................ 24 Item 14 Client Referrals and Other Compensa(cid:415)on .............................................................................................. 24 Item 15 Custody ................................................................................................................................................... 24 Item 16 Investment Discre(cid:415)on ............................................................................................................................ 25 Item 17 Vo(cid:415)ng Client Securi(cid:415)es........................................................................................................................... 25 Item 18 Financial Informa(cid:415)on ............................................................................................................................. 26 Other Informa(cid:415)on - Privacy No(cid:415)ce ..................................................................................................................... 27 Page 3 of 28  Item 4 Advisory Business A. Principal Owners and Firm Background McElhenny Sheffield Capital Management, LLC (“MSCM” or “Adviser”), a Texas limited liability company, is majority owned and controlled by its founder, Bruce McElhenny Fraser Jr. and his family. Mr. Fraser (the “Principal”) is the Managing Member, Managing Partner (func(cid:415)onal (cid:415)tle), and Chief Compliance Officer of MSCM. MSCM was founded by Mr. Fraser in 2000 and has its principal place of business in Dallas, Texas. Addi(cid:415)onal informa(cid:415)on rela(cid:415)ng to MSCM’s ownership can be found on Schedule A of MSCM’s Form ADV Part 1A. B. Types of Advisory Services The Adviser currently provides investment management services primarily through separately managed accounts (“Separately Managed Accounts”) for individuals, high net worth individuals, businesses and other institutions or entities, including as a sub-adviser to other investment advisers (collectively the “Clients”). MSCM provides the following tactical exchange-traded fund (“ETF”) strategies (“Tactical Strategies”): (1) Trend Plus, (2) Sector Rotation, (3) TPSR, (4) Trend X, and (5) other customized strategies based on a rules-based process managed by MSCM in the following styles: trend following, momentum, or a blend of trend following and momentum. Trend following seeks to participate in market upside while avoiding market downside. Momentum investing seeks to capitalize on sectors and market segments with strong momentum while avoiding markets that exhibit weakness. As described in Item 8 Methods of Analysis, Investment Strategies and Risk of Loss, the Trend X strategy uses leveraged ETFs and the use of leverage in a strategy will increase volatility and can exacerbate the movements of the account values in both directions up and down, depending on market movements. The Trend X strategy is intended for Qualified Clients only that have a high-risk tolerance and are willing to accept the risk of loss of their principal. See Item 8 for additional information about Leveraged ETFs. MSCM’s investment advisory services also include providing investment advice on equi(cid:415)es, debt, op(cid:415)ons, futures, ETFs, mutual funds, variable insurance vehicles, and other investment opportuni(cid:415)es for Separately Managed Accounts. In selec(cid:415)ng investment opportuni(cid:415)es, MSCM’s investment adviser representa(cid:415)ves will select what is believed to be the best opportunity for the Client based on various considera(cid:415)ons which poten(cid:415)ally will not be based on lowest price (e.g., trading volume and trading history of one ETF over another). The Tactical Strategies use proprietary quantitative algorithms (“Quantitative Models”) that are momentum or trend based and assist the portfolio managers, Bruce Fraser, the Managing Member, and Grant Morris, Director of Operations ( the “Portfolio Managers”), in determining what market exposure or which sectors and/or ETFs to allocate to within each Tactical Strategy. The Tactical Strategies seek to achieve their investment objectives while adhering to explicit risk controls that allow the portfolios to move to defensive positions of cash or non-equity asset classes during periods of elevated risk or market drawdowns. Trading activity is directed by outputs from the Quantitative Models that are developed, maintained, and implemented by the Portfolio Managers. The Quantitative Models are updated each day with the relevant market data and recalculated with the new data set. The Quantitative Model output is the market exposure and allocation that each Tactical Strategy should have each day. The spreadsheets are maintained for error-checking of the input data, model calculations, and output signals. Changes in allocations necessitate trades that are executed by the portfolio managers through block trading, which ensures that each Separately Managed Account assigned to the Quantitative Model receives the same execution at each Custodian. The trades indicated by the models are overridden only when extraordinary circumstances demand human intervention. The Portfolio Managers are the only persons that have the authority to override the Page 4 of 28  Quantitative Models’ recommendations, and they would only exercise this authority in a time of extreme market duress, or if a trade indicated by the Quantitative Models appears erroneous. The ongoing process includes constant monitoring of market and economic conditions as well as aggregate portfolio risks. To the extent recommendations are overridden or changes are made to the Quantitative Models, the Portfolio Managers will document such modifications and actions taken. MSCM’s trading strategies and Quantitative Models are revised from time to time as a result of ongoing research and development. The strategies and systems used by us in the future can differ significantly from those presently used, due to changes resulting from this research. In any event, the Firm will document when major changes are made to strategies and systems utilized, and will update this Brochure as deemed appropriate. The Tactical Strategies that we deploy on behalf of Clients are highly complex. The successful deployment of the Tactical Strategies requires sophisticated mathematical calculations and complex computer programs. Although we intend to use good faith efforts to carry out such calculations and programs correctly and to use them effectively, there can be no assurance that we will successfully do so. Errors can occur in designing, writing, testing, monitoring, and/or implementing such calculations and programs, including errors in the manner in which such calculations and programs function together. Any such error can be difficult to detect, will potentially not be detected for a significant period of time, and can have a material adverse effect on Clients. This risk can be exacerbated by the fact that the Tactical Strategies deployed by us are expected to include executing multiple trades over a particular time period, which can result in many trades being affected by any such error before it can be detected and corrected. In addition, such calculations and programs are dependent upon accurate market and other data, and inaccuracies in or any corruption of such data (or errors in incorporating such data) can have a material adverse effect on the results of such calculations and programs. Moreover, the effectiveness of such calculations and programs can diminish over time, including as a result of market changes and changes in the behavior of other market participants. In the event we determine that there is diminishing effectiveness, the Portfolio Managers will review the data and make certain changes to the program and/or the manner in which it is implemented, in the Portfolio Managers’ discretion. Any such changes can also increase the likelihood of the errors described above. The complexity of the components of the Tactical Strategies that apply to such calculations and programs, and the interactions among such components, can make it difficult or impossible to detect the source of any weakness or failure in such components and/or such calculations and programs before material losses are incurred. For example, it can be difficult or impossible to distinguish unexpected trading results caused by market activity from unexpected trading results caused by an error in the applicable calculations or programs. The mathematical calculations and computer programs utilized by us are subject to inherent limitations and can potentially be improved upon as experience is gained, strategies are refined, and markets change. However, there can be no assurances that we would be able to or will make any such improvements, and our inability or failure to do so can have a material adverse effect on Clients. We carry out our investment process and risk control procedures, in part, by applying Quantitative Models developed by the Portfolio Managers. Because our trading methods are proprietary, an investor will not be able to determine specific details of our methods or whether Quantitative Models are being followed. As a result, the Portfolio Managers will regularly monitor the program, and back test the equations as needed. MSCM is the discre(cid:415)onary sub-adviser of an ac(cid:415)vely managed ETF (“MSMR Fund” or “Fund”), organized to invest in shares of other ETFs (“Underlying Investments”) that reflect MSCM’s trend following and momentum strategies. MSCM will generally allocate approximately 50% of the Fund’s assets to each of its Trend Plus and Sector Rota(cid:415)on strategies, although such alloca(cid:415)ons can poten(cid:415)ally vary over (cid:415)me in response to market movements. The Fund’s Prospectus and Statement of Addi(cid:415)onal Informa(cid:415)on (“SAI”) Page 5 of 28  contain addi(cid:415)onal informa(cid:415)on about the Tac(cid:415)cal Strategies and disclosures rela(cid:415)ng to the Fund. Prior to making any investment in the Fund, Clients should carefully review these documents for a comprehensive understanding of the terms and condi(cid:415)ons applicable for investment. Because investments in the Fund involve certain addi(cid:415)onal degrees of risk, they will only be implemented or recommended when consistent with the Client's stated investment objec(cid:415)ves, tolerance for risk, liquidity, and suitability. The Fund assets are managed on a discre(cid:415)onary basis with MSCM, as sub-advisor providing supervisory management services and assis(cid:415)ng the Fund adviser in the coordina(cid:415)on of trade orders. The Fund’s investment adviser is responsible for trade execu(cid:415)on. MSCM also offers model por(cid:414)olio services to third par(cid:415)es (“Model Por(cid:414)olios”) that use the Model Por(cid:414)olios to provide investment advisory services to their clients on an investment pla(cid:414)orm or through other arrangements supervised by the third party. For the Model Por(cid:414)olios, MSCM delivers the Model Por(cid:414)olios and is not responsible for the coordina(cid:415)on of trade orders or execu(cid:415)on. Addi(cid:415)onally, the Adviser provides financial planning services for Clients. Clients receive a wri(cid:425)en or an electronic report, providing the Client with a financial plan designed to achieve their stated financial goals and objec(cid:415)ves. The Client and Adviser will work together to select the specific areas to cover. In general, the financial plan will generally address any or all of the following areas of concern: business planning, cash flow and debt management, college savings, employee benefits op(cid:415)miza(cid:415)on, estate planning, re(cid:415)rement planning, and investment analysis. C. Tailoring of Advisory Services The investment strategy of each account is tailored to the objec(cid:415)ves of the respec(cid:415)ve Client. Pursuant to the respec(cid:415)ve investment management agreements between the Adviser and the Clients (“IMA”), the Adviser is generally granted investment discre(cid:415)on with respect to the Separately Managed Accounts. However, such discre(cid:415)on is limited based on the par(cid:415)cular investment objec(cid:415)ves, preferences, guidelines and restric(cid:415)ons outlined in each Client’s IMA and for certain Clients, MSCM does not have discre(cid:415)on or involvement with trade placement and execu(cid:415)on, as discussed above. With respect to the financial planning services, specific Client financial plans and their implementa(cid:415)on are dependent upon the Client Investment Policy Statement which outlines each Client’s current situa(cid:415)on (income, tax levels and risk tolerance levels) and is used to construct a Client-specific plan to aid in the selec(cid:415)on of a por(cid:414)olio that matches restric(cid:415)ons, needs and targets. D. Wrap Fee Programs The Adviser does not par(cid:415)cipate in wrap fee programs. E. Assets Under Management As of December 31, 2024, the Adviser had $560.4 million in assets under management represen(cid:415)ng $508.7 million in regulatory assets under management managed on a discre(cid:415)onary basis, subject to limita(cid:415)ons set forth in each Client’s IMA, and $51.8 million of assets managed for Model Por(cid:414)olios that are not included in regulatory assets under management. Page 6 of 28  Item 5 Fees and Compensa(cid:415)on A. Compensa(cid:415)on 1. Management Fee Our standard IMA provides for a management fee (“Management Fee”) of up to 2% per annum of the value of the account subject to the IMA. One-twel(cid:332)h (1/12) of the annual Management Fee will be debited against each Client account at the beginning of each month. The Adviser, in its sole discre(cid:415)on, reduces or waives all or any part of the Management Fee and certain Clients do not pay a separate asset management fee for Separately Managed Accounts inves(cid:415)ng in the Fund. Management Fees are nego(cid:415)able. When MSCM acts as an investment adviser, MSCM is required to act in the Client’s best interest and not put its interests ahead of Clients. At the same (cid:415)me, the way MSCM makes money creates some conflicts with Client interests. Here are some examples:  MSCM has an incen(cid:415)ve to increase the assets in Separately Managed Accounts to increase fees. MSCM charges asset-based fees and therefore makes more money when there is an increase in the assets in Separately Managed Accounts. Therefore, MSCM has an incen(cid:415)ve to recommend increasing the assets in Separately Managed Accounts. MSCM’s financial professionals earn compensa(cid:415)on based upon a por(cid:415)on of the revenue MSCM earns from Clients for providing Clients with advisory services. As a result, MSCM’s financial professionals have a financial incen(cid:415)ve to not reduce fees.  Clients pay MSCM’s fee monthly even if there is limited or no investment ac(cid:415)vity in the Client account. Clients pay fees and costs whether Clients make or lose money on their investments. Fees and costs will reduce any amount of money Clients make on their investments over (cid:415)me.  MSCM has an incen(cid:415)ve to recommend margin accounts to permit borrowing money for a Client account. Addi(cid:415)onally, for margin loans, the purchase of securi(cid:415)es in the account will result in increased asset-based fees, which provides an incen(cid:415)ve for MSCM to recommend the use of margin.  MSCM earns higher management fees when MSCM invests Separately Managed Accounts in the Fund. The receipt of addi(cid:415)onal compensa(cid:415)on from the Fund provides an incen(cid:415)ve for MSCM to invest Client assets in the Fund. The fees charged for financial advisory services, together with fees paid to MSCM indirectly through the Fund, can be higher than the fees charged by other investment advisers for similar investment advisory services. Clients can independently and directly invest in the Fund through other financial services firms/broker-dealers. 2. MSMR Fund Sub-Advisory Fee As sub-adviser to the Fund, MSCM is paid a fee by the adviser of the Fund, which is calculated daily and paid monthly, at an annual rate based on the average daily net assets of the Fund of 0 0.64%, as disclosed in the Fund prospectus. MSCM recommends, when it is determined to be appropriate for Clients, that Clients invest in the Fund for which it serves as sub-adviser and for which MSCM is paid a fee by the adviser of the Fund. The Por(cid:414)olio Managers each receive compensa(cid:415)on based on firm revenue which includes the sub-adviser fee paid by the Fund. The compensa(cid:415)on is not based on referral of Clients or securi(cid:415)es transac(cid:415)ons. MSCM does not have an ownership or sales interest in the Fund. Page 7 of 28  Under normal circumstances and in accordance with the Client’s established Investment Plan and risk tolerance, MSCM will recommend investments on a discre(cid:415)onary basis that include the Fund. Clients inves(cid:415)ng in the Fund will generally be subject to both the Fund’s management fees (a por(cid:415)on of which are payable to MSCM and indirectly to the Por(cid:414)olio Managers) and MSCM’s Management Fee. The receipt of addi(cid:415)onal compensa(cid:415)on from the Fund provides an incen(cid:415)ve for MSCM to invest Client assets in the Fund. The fees charged for por(cid:414)olio management services, together with fees paid to MSCM indirectly through the Fund, can be higher than the fees charged by other investment advisers for similar investment advisory services. Clients can also independently invest in Fund shares through other financial services firms/broker- dealers. 3. Performance-Based Fee For certain Clients for which the Adviser manages the en(cid:415)re investment account in our Trend X strategy, the Adviser will generally charge a quarterly fee, subject to a high-water mark (a “Performance-Based Fee”). With respect to such Clients, Performance-Based Fees will be up to 20% based on the net profits generated in the Client’s por(cid:414)olio during the quarter (subject to the aforemen(cid:415)oned high-water mark). The Adviser, in its sole discre(cid:415)on, reduces or waives all or any part of the Performance-Based Fee. Performance-Based Fees are nego(cid:415)able. Clients will only be charged a Performance-based Fee if they meet the defini(cid:415)on of “Qualified Client” as defined in Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”). Performance-Based Fees payable to Adviser, if any, will generally be debited against each Client account at the beginning of each quarter. 4. Financial Planning Services Fee Financial Planning will generally be offered on either a fixed-fee basis or on an hourly basis at an approximate rate of $250 per hour, depending on the nature of the specified services. Fees will be determined on a case-by-case basis with the fee based on the complexity of the situa(cid:415)on and the needs of the Client. The fixed fee will generally be up to $5,000. The fixed fee or hourly rate will be agreed upon before the start of any work. Financial planning fees are nego(cid:415)able. B. How Fees Are Collected The Adviser will direct the custodian (the “Custodian”) of each Client account, with the authoriza(cid:415)on of the Client, to withdraw funds to pay the Adviser’s management and Performance-Based Fees. One-twel(cid:332)h (1/12) of the annual Management Fee will be debited against each Client account at the beginning of each month. The Performance-Based Fees payable to Adviser, if any, will generally be debited against each Client account at the beginning of each quarter. With respect to any Clients for whom the Adviser currently provides investment management services, the Adviser will direct the Custodian of each Client account, with the authoriza(cid:415)on of the Client, to withdraw funds to pay the Adviser’s financial planning fees. With respect to any Clients for whom the Adviser does not currently provide investment management services, the Client will generally pay the Adviser via check. C. Other Fees or Expenses Separately Managed Accounts will bear their own expenses, including but not limited to, transac(cid:415)on, exchange, wire transfer, and margin interest expenses. Clients will pay transac(cid:415)on fees, and other transac(cid:415)on-related third-party costs and expenses incurred in the management of Client assets. By way of Page 8 of 28  example, these costs include charges imposed by Custodians, and others, such as custodial fees, deferred sales charges, wire transfer and electronic fund fees, and other fees and taxes on custodial brokerage accounts and securi(cid:415)es transac(cid:415)ons. Some investments (e.g., mutual funds, ETFs, and variable insurance vehicles) impose addi(cid:415)onal fees that will reduce the value of a Client’s investment over (cid:415)me. When Clients invest in variable insurance vehicles, MSCM receives a periodic management fee from the variable insurance vehicle issuer and the management fee paid to MSCM is fully passed through from MSCM to the investment adviser representa(cid:415)ve recommending the variable insurance vehicle to the Client. Client investment in ETFs and other investment vehicles, including the Fund, will generally be subject to both the investment vehicles’ management fees (with respect to the Fund, a por(cid:415)on of which are payable to MSCM, as sub-adviser) and MSCM’s management fee. The Adviser, in its sole discre(cid:415)on, reduces or waives all or any part of the Management Fee and certain Clients do not pay a separate asset management fee for investment in the Fund. D. Advanced Payment Management Fees are generally payable in advance. If a Client terminates the advisory contract prior to the end of the billing period, the Client is en(cid:415)tled to a refund of prepaid fees on a prorated basis. Due to Client custodial arrangements and the method of termina(cid:415)on resul(cid:415)ng in assets under management being removed from the account, it will be the responsibility of the Client to request a refund for prepaid fees. The amount of the refund will be calculated using the value of the Client’s investment on the last trading day of the prior billing period. E. Compensa(cid:415)on for Sales of Securi(cid:415)es Neither MSCM nor any of its officers, Members, employees, and investment adviser representa(cid:415)ves as well as to any other person who provides investment advice on behalf of the Adviser and who is subject to the Adviser’s supervision and control (“Supervised Persons”) accept compensa(cid:415)on for the sale of securi(cid:415)es or other investment products. See Item 10: Other Financial Industry Ac(cid:415)vi(cid:415)es and Affilia(cid:415)ons for disclosure of certain outside business ac(cid:415)vi(cid:415)es of Supervised Persons. F. Re(cid:415)rement Accounts We are fiduciaries to our Clients under the Advisers Act and also fiduciaries within the meaning of Title I of the Employee Re(cid:415)rement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, when we provide investment advice regarding por(cid:414)olio assets held in an IRA, Roth IRA, Archer Medical Savings Account, a Plan covered by ERISA, or a plan described in Sec(cid:415)on 4975(e)(1)(A) of the IRC (collec(cid:415)vely referred to collec(cid:415)vely some(cid:415)mes herein as (“Re(cid:415)rement Accounts”). To ensure that MSCM will adhere to fiduciary norms and basic standards of fair dealing, we are required to give advice that is in the "best interest" of a Re(cid:415)rement Account Client. The best interest standard has two chief components, prudence, and loyalty. Under the prudence standard, the advice must meet a professional standard of care and under the loyalty standard, our advice must be based on the interests of our Re(cid:415)rement Account Clients, rather than the poten(cid:415)al compe(cid:415)ng financial interest of MSCM. To address the conflicts of interest with respect to our compensa(cid:415)on, we are required to act in your best interest and not put our interest ahead of yours. To this end, we must: Page 9 of 28   Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put our financial interests ahead of yours when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that we give advice that is in your best interest;  Charge no more than is reasonable for our services; and  Give you basic information about conflicts of interest. Item 6 Performance-Based Fees and Side-By-Side Management As explained above, the Adviser charges Performance-Based Fees with respect to certain strategies for certain Qualified Clients. The Adviser manages both accounts that are charged a Performance-Based Fee and accounts that are not charged a Performance-Based Fee (“Side-by-Side Management”). The Adviser has an incen(cid:415)ve to favor accounts that are charged a Performance-Based Fee and has adopted reasonable controls (e.g., trade aggrega(cid:415)on) to ensure that Performance-Based Fee clients are not favored over other Clients. Charging a Performance-Based Fee creates an incen(cid:415)ve for the Adviser to make investments that are riskier or more specula(cid:415)ve than would be the case in the absence of a fee based on the performance of the account. Item 7 Types of Clients MSCM, in its sole discre(cid:415)on, manages Clients with different objec(cid:415)ves, higher or lower fees and different fee structures than what is described in this brochure. MSCM provides investment management services to individuals, high net worth individuals, businesses and other ins(cid:415)tu(cid:415)ons or en(cid:415)(cid:415)es, including Re(cid:415)rement Accounts, primarily through Separately Managed Accounts over which MSCM has discre(cid:415)on. The Adviser also provides financial planning services for Clients, serves as a sub-adviser to other investment advisers, and offers Model Por(cid:414)olios to other investment advisers and financial pla(cid:414)orms. There are no material limita(cid:415)ons and no minimum requirements for Separately Managed Clients to open an account or establish an advisory rela(cid:415)onship. Separately Managed Accounts will be managed in accordance with the investment objec(cid:415)ves, guidelines, restric(cid:415)ons, and other informa(cid:415)on provided by the Separately Managed Account Client to the Adviser in the Suitability Ques(cid:415)onnaire, which is included in the IMA. Notwithstanding any provisions in the IMA, federal and state securi(cid:415)es laws impose liability under certain circumstances on persons who act in good faith and nothing in the IMA purports to waive or limit any rights that Clients have under those laws (“Reserved Rights”). CLIENTS HAVE RESERVED RIGHTS AND THEREFORE NOTHING IN THE IMA PURPORTS TO WAIVE OR LIMIT ANY RESERVED RIGHTS THAT CLIENTS HAVE UNDER THOSE LAWS. MSCM charges Qualified Clients a Performance-Based Fee with respect to certain strategies, such as MSCM’s Trend X strategy. However, to comply with SEC Rule 205-3, MSCM will only charge a Performance- Based Fee to Qualified Clients. Page 10 of 28  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Analysis and Strategies MSCM provides investment advisory services to Separately Managed Accounts based on the investment objec(cid:415)ves, guidelines, restric(cid:415)ons, and other informa(cid:415)on provided by the Separately Managed Account and according to investment mandates provided by other Clients. The overall objec(cid:415)ve in managing Clients is to seek to achieve capital apprecia(cid:415)on by inves(cid:415)ng in and trading securi(cid:415)es consis(cid:415)ng of equity and equity related securi(cid:415)es that are publicly traded on U.S. exchanges. MSCM will invest Clients in a wide range of securi(cid:415)es and other financial instruments including, but not limited to, exchange listed and over the-counter equity securi(cid:415)es, preferred stocks, conver(cid:415)ble securi(cid:415)es, exchange-traded funds, warrants, rights, op(cid:415)ons, corporate and municipal debt securi(cid:415)es, and U.S. government securi(cid:415)es. Clients managed by MSCM own long posi(cid:415)ons and poten(cid:415)ally sell short posi(cid:415)ons. MSCM’s Tac(cid:415)cal Strategies are heavily dependent on proprietary Quan(cid:415)ta(cid:415)ve Models as well as informa(cid:415)on and data supplied by third par(cid:415)es. The Adviser uses a variety of methods for analyzing and designing Client por(cid:414)olios including fundamental analysis and standard risk assessment tools. The sources used for financial analysis and research include financial publica(cid:415)ons, prospectuses, annual reports and internet data sources. B. Material Risks Inves(cid:415)ng in securi(cid:415)es involves risk of loss that Clients should be prepared to bear. All investments in securi(cid:415)es include a risk of loss of a Client’s principal investment as well as any previously realized or unrealized profits. Stock and bond markets fluctuate substan(cid:415)ally over (cid:415)me. In addi(cid:415)on to market risk, certain other risk factors poten(cid:415)ally affect the performance of Clients accounts over (cid:415)me, including interest rate risk, infla(cid:415)on risk, currency risk, liquidity risk and sociopoli(cid:415)cal risk, among others. The various risks summarized below are not the only risks associated with the Adviser’s investment strategies and processes. Clients are urged to consult with independent financial, legal and tax advisors. Certain of the risks are summarized as follows:  Competition: The investment management industry, in general, and the markets in which the Adviser trades are extremely competitive. In pursuing its trading methods and strategies, the Adviser will compete with investment firms, including many of the larger investment advisory and private investment firms, as well as institutional investors and, in certain circumstances, market makers, banks and broker-dealers. As a result of such competition, market opportunities in which the Tactical Strategies seek to capitalize can be short-lived or disappear and profit potential can be materially reduced. There can be no assurance that the Adviser will be able to find suitable opportunities consistent with its investment approach.  Currency Exchange Rates: To the extent the Tactical Strategies invest in U.S. Dollar ETFs, changes in currency exchange rates and the relative value of non-U.S. currencies will affect the value of the strategy. Currency exchange rates can be very volatile and can change quickly and unpredictably. As a result, the value of an investment can also change quickly, unpredictably, and without warning, and you can lose money.  Cybersecurity Breaches and Iden(cid:415)ty The(cid:332): Informa(cid:415)on and technology systems of the Adviser, por(cid:414)olio companies in which Clients are invested and the Adviser’s service providers can be vulnerable to damage or interrup(cid:415)on from computer viruses, network failures, computer and telecommunica(cid:415)on failures, infiltra(cid:415)on by unauthorized persons and security breaches, usage Page 11 of 28  errors by their respec(cid:415)ve professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. If any systems designed to manage such risks are compromised, become inoperable for extended periods of (cid:415)me, or cease to func(cid:415)on properly, the Adviser, a por(cid:414)olio company in which Clients are invested and/or a service provider can have to make a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason can cause significant interrup(cid:415)ons in the Adviser, a por(cid:414)olio company in which an account is invested and/or a service provider’s opera(cid:415)ons and result in a failure to maintain the security, confiden(cid:415)ality, or privacy of sensi(cid:415)ve data, including personal informa(cid:415)on rela(cid:415)ng to Clients. Such a failure can harm the Adviser’s, a por(cid:414)olio company’s (in which Clients are invested) or a service provider’s reputa(cid:415)on, subject them and their respec(cid:415)ve affiliates to legal claims and otherwise affect their business and financial performance.  Derivatives: Credit default swaps and similar derivative instruments used for hedging purposes present risks that are different from traditional securities. There is a risk that the derivative will not correlate well to the security it is hedging. Further, it can be difficult to unwind derivative positions due to illiquidity in the markets. To the extent the Tactical Strategies invest in U.S. Dollar ETFs or Gold ETFs, the strategy is exposed, through those Underlying Investments, to derivative instruments, including forward currency contracts (with respect to U.S. Dollar ETFs) or futures contracts that correlate to the investment returns of physical gold (with respect to Gold ETFs). A U.S. Dollar ETF’s or Gold ETF’s use of derivatives can reduce its returns or increase volatility. Derivatives can also be subject to counterparty risk, which is the risk that the other party in the transaction will not fulfill its contractual obligation. Counterparty risk for over-the counter (“OTC”) derivatives is generally higher than that for derivatives traded on an exchange or through a clearing house. A risk of a U.S. Dollar ETF or Gold ETF’s use of derivatives is that the fluctuations in their values will potentially not correlate perfectly with the value of the underlying asset, the performance of the asset class to which the U.S. Dollar ETF or Gold ETF seeks exposure or the performance of the overall markets. The possible lack of a liquid secondary market for derivatives and the resulting inability of the U.S. Dollar ETF or Gold ETF to sell or otherwise close a derivatives position can expose the U.S. Dollar ETF or Gold ETF to losses and can make derivatives more difficult for the U.S. Dollar ETF or Gold ETF to value accurately. A U.S. Dollar ETF or Gold ETF can also suffer losses related to its derivatives positions as a result of unanticipated market movements, or movements between the time of periodic reallocations of strategy assets, which losses are potentially unlimited. Certain derivatives can give rise to a form of leverage and can expose the U.S. Dollar ETF or Gold ETF to greater risk and increase its costs. The impact of U.S. and global regulation of derivatives can make derivatives more costly, can limit the availability of derivatives, can delay or restrict the exercise by the U.S. Dollar ETF or Gold ETF of termination rights or remedies upon a counterparty default under derivatives held by the U.S. Dollar ETF or Gold ETF (which can result in losses), or can otherwise adversely affect the value or performance of derivatives. There can be no assurance that the Adviser will be able to find suitable opportunities to invest in derivatives consistent with its investment approach. In such circumstances, the Client will be restricted from full investment in the Tactical Strategy and performance results will be potentially impacted.  Commodity-Linked Derivatives. To the extent Tactical Strategies invest in Gold ETFs, the Tactical Strategy is exposed to commodity-linked derivatives. The value of a commodity-linked derivative investment typically is based upon the price movements of an underlying physical commodity (e.g., gold), and can be affected by changes in overall market movements, volatility of the market, changes in interest rates, or factors affecting a particular industry or commodity (e.g., drought, floods, weather, embargoes, tariffs and international economic, political and regulatory developments). Investments in commodity-linked derivatives can be subject to investments that are not derivative-based. Commodity-linked greater volatility than Page 12 of 28  derivatives also can be subject to credit and interest rate risks that in general affect the values of debt securities.  Futures Contracts. To the extent the Tactical Strategies invest in Gold ETFs, the strategy is exposed to exchange-traded futures contracts. Futures are standardized contracts that obligate a purchaser to take delivery, and a seller to make delivery, of a specific amount of an asset at a specified future date at a specified price. Unlike equities, which typically entitle the holder to a continuing ownership stake in an issuer, futures contracts normally specify a certain date for settlement in cash based on the level of the reference rate. The primary risks associated with the use of futures contracts are: (1) the imperfect correlation between the change in market value of the instruments held by a Gold ETF and the price of the futures contract; (2) possible lack of a liquid secondary market for a futures contract and the resulting inability to close a futures contract when desired; (3) losses caused by unanticipated market movements, which are potentially unlimited; (4) the inability of the Gold ETF’s investment adviser to predict correctly the direction of prices and other economic factors; and (5) the possibility that the counterparty will default in the performance of its obligations.  Forward Currency Contracts. To the extent the Tactical Strategies invest in U.S. Dollar ETFs, the strategy is exposed to forward currency contracts. A forward foreign currency exchange contract (“forward contract”) involves an obligation to purchase or sell a specific currency at a future date, which can be any fixed number of days from the date of the contract agreed upon by the parties, at a price set at the time of the contract. These contracts are principally traded in the interbank market conducted directly between currency traders (usually large commercial banks) and their customers. Forward contracts are contracts between parties in which one party agrees to make a payment to the other party (the counterparty) based on the market value or level of a specified currency. In return, the counterparty agrees to make payment to the first party based on the return of a different specified currency. A forward contract generally has no margin deposit requirement, and no commissions are charged at any stage for trades. These contracts typically are settled by physical delivery of the underlying currency or currencies in the amount of the full contract value. The primary risks associated with the use of forward currency contracts are: (1) the success of the ability of the U.S. Dollar ETF’s investment adviser to predict movements in the prices of individual currencies, fluctuations in markets and movements in interest rates; (2) the imperfect correlation between the change in market value of the instruments held by a U.S. Dollar ETF and the price of the forward contract; and (3) the possibility that the counterparty will default in the performance of its obligations.  Discre(cid:415)on; Investment Judgment: The Adviser generally has broad discre(cid:415)on with respect to the investment program of Clients, which involves assets that will be affected by various business, financial market, or legal uncertain(cid:415)es. Profitability depends to a great extent upon correctly evalua(cid:415)ng these uncertain(cid:415)es in order to assess the future course of the price movements of securi(cid:415)es and other investments. There can be no assurance that the Adviser will correctly evaluate the nature and magnitude of the various factors that can affect the value or return on investments. In addi(cid:415)on, changing market and economic condi(cid:415)ons can lead to Client losses.  Diversifica(cid:415)on: Certain por(cid:414)olios are not necessarily widely diversified. Thus, a Client’s account can be subject to more rapid changes in value than would be the case if the account were required to maintain a wide diversification among companies, securities and types of securities. This limited diversity can expose a Client’s account to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements in the Client’s investments. The Fund is considered to be non-diversified, which means that it can invest more of its assets in the securities of a single issuer or a smaller number of issuers than if it were a Page 13 of 28  diversified fund. As a result, the Fund will be more exposed to the risks associated with and developments affecting an individual issuer or a smaller number of issuers than a fund that invests more widely. This can increase the Fund’s volatility and cause the performance of a relatively smaller number of issuers to have a greater impact on the Fund’s performance.  Dividend-Paying Securities: There is no guarantee that issuers of the securities held by Underlying Investments will declare dividends in the future or that, if declared, they will either remain at current levels or increase over time. The strategy can also underperform similar strategies that invest without considering a company’s dividend payments. Companies that pay dividends historically will potentially not participate in a broad market advance to the same extent as other companies that do not pay dividends. Such companies can also be sensitive to a sharp rise in interest rates or an economic downturn that leads to the elimination or reduction of dividend payments to investors.  Equity Markets: Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. These investor perceptions are based on various and unpredictable factors including: expectations regarding government, economic, monetary and fiscal policies; inflation and interest rates; economic expansion or contraction; local, regional or global events (e.g., acts of terrorism or war); and global or regional political, economic, public health (e.g., pandemics), and banking crises. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer because common stockholders, or holders of equivalent interests, generally have inferior rights to receive payments from issuers in comparison with the rights of preferred stockholders, bondholders, and other creditors of such issuers.  ETFs:  Authorized Participants, Market Makers, and Liquidity Providers Concentration. ETFs have a limited number of financial institutions that act as Authorized Participants (“APs”). In addition, there can be a limited number of market makers and/or liquidity providers in the marketplace. To the extent either of the following events occur, ETF shares can trade at a material discount to NAV and possibly face delisting: (1) APs exit the business or otherwise become unable to process creation and/or redemption orders and no other APs step forward to perform these services, or (2) market makers and/or liquidity providers exit the business or significantly reduce their business activities and no other entities step forward to perform their functions.  Costs of Buying or Selling ETF Shares. Investors buying or selling ETF shares in the secondary market will pay brokerage commissions or other charges imposed by broker-dealers, as determined by that broker-dealer. Brokerage commissions are often a fixed amount and can be a significant proportional cost for investors seeking to buy or sell relatively small amounts of ETF Shares. In addition, secondary market investors will also incur the cost of the difference between the price at which an investor is willing to buy ETF shares (the “bid” price) and the price at which an investor is willing to sell ETF shares (the “ask” price). This difference in bid and ask prices is often referred to as the “spread” or “bid-ask spread.” The bid-ask spread varies over time for ETF shares based on trading volume and market liquidity, and the spread is generally lower if ETF shares have more trading volume and market liquidity and higher if ETF shares have little trading volume and market liquidity. Further, a relatively small investor base in the ETF, asset swings in the ETF, and/or increased market volatility can cause increased bid-ask spreads. Due to the costs of buying or selling ETF shares, including bid-ask spreads, frequent trading of ETF shares can significantly reduce investment results and an investment Page 14 of 28  in ETF shares will potentially not be advisable for investors who anticipate regularly making small investments.  ETF Shares Could Trade at Prices Other Than NAV. As with all ETFs, ETF shares can be bought and sold in the secondary market at market prices. Although it is expected that the market price of ETF shares will approximate the ETF’s NAV, there can be times when the market price of ETF shares is more than the NAV intra-day (premium) or less than the NAV intra-day (discount) due to supply and demand of ETF shares or during periods of market volatility. This risk is heightened in times of market volatility or periods of steep market declines. The market price of ETF shares during the trading day, like the price of any exchange traded security, includes a “bid-ask” spread charged by the exchange specialist, market makers or other participants that trade the ETF shares. In times of severe market disruption, the bid-ask spread can increase significantly. At those times, ETF shares are most likely to be traded at a discount to NAV, and the discount is likely to be greatest when the price of ETF shares is falling fastest, which can be the time that you most want to sell your ETF shares. The Adviser believes that, under normal market conditions, large market price discounts or premiums to NAV will not be sustained because of arbitrage opportunities.  Leveraged ETFs: The Trend X strategy uses leveraged ETFs and the use of leverage in a strategy will increase volatility and can exacerbate the movements of the account values in both directions up and down, depending on market movements. Leveraged ETFs seek to deliver multiples of the daily performance of the index or benchmark they track. For example, a 2x (two times) leveraged ETF seeks to deliver double the daily performance of the index or benchmark that it tracks. Like traditional ETFs, some leveraged ETFs track broad indices, some are sector-specific, and others are linked to some other benchmark. To accomplish their objectives, leveraged ETFs pursue a range of investment strategies through the use of swaps, futures contracts, and other derivative instruments. Most leveraged and inverse ETFs “reset” daily, meaning that they are designed to achieve their stated objectives on a daily basis. Their performance over longer periods of time -- over weeks or months or years -- can differ significantly from the stated multiple of the performance (or inverse of the performance) of their underlying index or benchmark during the same period of time. This effect can be magnified in volatile markets. An ETF that is set up to deliver twice the performance of a benchmark from the close of trading on Day 1 to the close of trading on Day 2 typically will not achieve that goal over weeks, months, or years and may potentially expose investors to significant and sudden losses. Clients can read additional information about the risk of leveraged ETF in an SEC Investor Bulletin: Leveraged and Inverse ETFs available at Investor.gov and from MSCM. At the time of filing this disclosure brochure, MSCM is generally using one leveraged ETF in the Trend X strategy, ProShares UltraPro QQQ on a short-term intermittent basis. As noted in Item 7, only sophisticated clients that meet Rule 205-3 definition of “Qualified Client” can invest in the Trend X strategy.  Trading. Although ETF shares are listed for trading on a stock exchange and can be listed or traded on U.S. and non-U.S. stock exchanges, there can be no assurance that an active trading market for ETF shares will develop or be maintained. Trading in ETF shares can be halted due to market conditions or for reasons that, in the view of the stock exchange, make trading in ETF shares inadvisable. In addition, trading in ETF shares on the stock exchange is subject to trading halts caused by extraordinary market volatility pursuant to the stock exchange “circuit breaker” rules, which temporarily halt trading on the stock exchange when a decline in the S&P 500® Index during a single day reaches certain thresholds (e.g., 7%, 13%, and 20%). Page 15 of 28  Additional rules applicable to the stock exchange can halt trading in ETF shares when extraordinary volatility causes sudden, significant swings in the market price of ETF shares. There can be no assurance that ETF shares will trade with any volume, or at all, on any stock exchange. In stressed market conditions, the liquidity of ETF shares can begin to mirror the liquidity of the ETF’s underlying portfolio holdings, which can be significantly less liquid than the ETF shares, and this can lead to differences between the market price of the ETF shares and the underlying value of those ETF shares.  Fixed Income Securities: Fixed income securities (e.g., bonds and certain asset-backed securities), involve certain risks, which include:  Calls. During periods of falling interest rates, an issuer of a callable bond held by an Underlying Investment can “call” or repay the security before its stated maturity, and the Underlying Investment can have to reinvest the proceeds in securities with lower yields, which would result in a decline in that fund’s income, or in securities with greater risks or with other less favorable features.  Credit. Credit risk refers to the possibility that the issuer of a security will not be able to make principal and interest payments when due. Changes in an issuer’s credit rating or the market’s perception of an issuer’s creditworthiness can also affect the value of the Underlying Investment’s investment in that issuer. The degree of credit risk depends on both the financial condition of the issuer and the terms of the obligation.  Duration. Prices of fixed income securities with longer durations are more sensitive to interest rate changes than those with shorter durations.  Events. Event risk is the risk that corporate issuers can undergo restructurings, such as mergers, leveraged buyouts, takeovers, or similar events financed by increased debt. As a result of the added debt, the credit quality and market value of a company’s bonds and/or other debt securities can decline significantly.  Extensions. When interest rates rise, certain obligations will be paid off by the obligor more slowly than anticipated, causing the value of these securities to fall. Rising interest rates tend to extend the duration of securities, making them more sensitive to future changes in interest rates. The value of longer-term securities generally changes more in response to changes in interest rates than the value of shorter-term securities. As a result, in a period of rising interest rates, securities can exhibit additional volatility and can lose value.  Interest Rates. Generally, the value of fixed income securities will change inversely with changes in interest rates. As interest rates rise, the market value of fixed income securities tends to decrease. Conversely, as interest rates fall, the market value of fixed income securities tends to increase. This risk will be greater for long-term securities than for short- term securities. An Underlying Investment can take steps to attempt to reduce the exposure of its portfolio to interest rate changes; however, there can be no guarantee that a Fund will take such actions or that the Fund will be successful in reducing the impact of interest rate changes on the portfolio. Changes in government intervention can have adverse effects on investments, volatility, and illiquidity in debt markets.  Maturity. The value of fixed income investments is also dependent on their maturity. Generally, the longer the maturity of a fixed income security, the greater its sensitivity to changes in interest rates.  Prepayment. When interest rates fall, certain obligations will be paid off by the obligor more quickly than originally anticipated, and an Underlying Investment can have to invest the proceeds in securities with lower yields. In periods of falling interest rates, the rate of Page 16 of 28  prepayments tends to increase (as does price fluctuation) as borrowers are motivated to pay off debt and refinance at new lower rates. During such periods, reinvestment of the prepayment proceeds by the management team will generally be at lower rates of return than the return on the assets that were prepaid. Prepayment reduces the yield to maturity and the average life of the security.  Variable and Floating Rate Instruments. The absence of an active market for these securities can make it difficult for the Underlying Investment to dispose of them if the issuer defaults.  Government Obligations: The Tactical Strategies can invest in securities issued by the U.S. government either directly or through investments in Underlying Investments that invest in such securities. Downgrades can increase volatility in domestic and foreign financial markets, result in higher interest rates, lower prices of U.S. Treasury securities and increase the costs of different kinds of debt. Any controversy or ongoing uncertainty regarding the statutory debt ceiling negotiations can impact the U.S. long-term sovereign credit rating and can cause market uncertainty. As a result, market prices and yields of securities supported by the full faith and credit of the U.S. government can be adversely affected.  High Portfolio Turnover: The Tactical Strategies can frequently buy and sell portfolio securities and other assets to rebalance the strategy’s exposure to specific securities. Higher portfolio turnover can result in higher levels of transaction costs and generating greater tax liabilities. Portfolio turnover risk can cause the strategy’s performance to be less than you expect.  Investment Due Diligence and Research; Reliance on Corporate Management and Financial Reporting: In certain instances, due diligence information available to the Adviser at the time of an investment decision is limited, and the Adviser can have neither access to adequately granular information nor adequate time to analyze the information necessary for a complete evaluation of the investment opportunity. It is also possible that the due diligence and research conducted does not reveal all the relevant facts and information that are necessary to evaluate such investment opportunity. In the worst-case scenario, information can be manipulated or fraudulent. Clients can incur material losses as a result of the misconduct or incompetence of such individuals and/or a substantial inaccuracy in such information.  Macroeconomics: Fluctuations in interest rates can cause investment prices to fluctuate. The inflation rate can increase, causing a decrease in purchasing power. Returns will be affected by general economic and market conditions such as economic uncertainty, commodity prices, currency rates, changes in credit availability, and changes in laws and many others.  Management: The Tactical Strategies are actively managed and potentially will not meet its investment objective based on the Adviser’s success or failure to implement investment strategies.  Margin: When Clients invest on margin, Clients are borrowing money from their Custodian to buy stocks and use their investment as collateral. This allows Clients to increase their purchasing power and own more stock without fully paying for it. However, it also exposes Clients to the potential for higher losses. In volatile markets, Client who put up an initial margin payment for a can, from time-to-time, be required to provide additional cash if the price of the stock falls. Margin accounts can be very risky and they are not suitable for everyone. Before opening a margin account, Clients should fully understand that: (1) Clients can lose more money than the Client has invested, (2) Clients potentially will have to deposit additional cash or securities in their account on short notice to cover market losses, (3) Clients can be forced to sell some or all of their securities when falling stock prices reduce the value of their securities and (4) the Client’s Page 17 of 28  Custodian can potentially sell some or all of the Client’s securities without consulting the Client to pay off the loan it made to the Client.  Market Capitalization:  Large-Capitalization Investing. The securities of large-capitalization companies can be relatively mature compared to smaller companies and therefore subject to slower growth during times of economic expansion. Large-capitalization companies can also be unable to respond quickly to new competitive challenges, such as changes in technology and consumer tastes.  Mid-Capitalization Investing. The securities of mid-capitalization companies can be more vulnerable to adverse issuer, market, political, or economic developments than securities of large-capitalization companies, but they can also be subject to slower growth than small- capitalization companies during times of economic expansion. The securities of mid- capitalization companies generally trade in lower volumes and are subject to greater and more unpredictable price changes than large capitalization stocks or the stock market as a whole, but they can also be nimbler and more responsive to new challenges than large-capitalization companies. Some mid-capitalization companies have limited product lines, markets, financial resources, and management personnel and tend to concentrate on fewer geographical markets relative to large-capitalization companies. is typically less publicly available  Small-Capitalization Investing. The securities of small-capitalization companies can be more vulnerable to adverse issuer, market, political, or economic developments than securities of larger-capitalization companies. The securities of small capitalization companies generally trade in lower volumes and are subject to greater and more unpredictable price changes than larger capitalization stocks or the stock market as a whole. Some small capitalization companies have limited product lines, markets, and financial and managerial resources and tend to concentrate on fewer geographical markets relative to larger capitalization companies. information concerning smaller-capitalization There companies than for larger, more established companies. Small-capitalization companies also can be particularly sensitive to changes in interest rates, government regulation, borrowing costs and earnings.  Market Risks in General: The Tactical Strategies are subject to market risk, including, but not limited to, changes in the regulatory environment, “flights to quality” and “credit squeezes.” The particular or general types of market conditions in which losses can be incurred or unexpected performance volatility can be experienced cannot be predicted, and the Adviser’s strategies can materially underperform other investment funds or accounts with substantially similar investment objectives and approaches.  Poten(cid:415)al Loss of Investment: Any investment in securi(cid:415)es involves risk. There can be no assurance that the Adviser’s strategy will achieve the Client’s investment objectives or that Clients will not lose all or substantially all of their investment.  Quantitative Models and Data Risk: MSCM’s strategies are heavily dependent on Quantitative Models as well as information and data supplied by third parties. When Quantitative Models and data supplied by third parties prove to be incorrect or incomplete, any decisions made in reliance thereon can lead to securities being purchased, held, or sold that would not have been purchased, held, or sold had the Models and Data been correct and complete. The Quantitative Models are predictive in nature. The use of Quantitative Models have inherent risks (e.g., Quantitative Models can incorrectly forecast future behavior, leading to potential losses on a cash flow and/or a mark- to-market basis). In addition, in unforeseen or certain low-probability scenarios (often involving a Page 18 of 28  market disruption of some kind), Quantitative Models can produce unexpected results, which can result in losses. Furthermore, because predictive models are usually constructed based on historical data supplied by third parties, the success of relying on Quantitative Models can depend heavily on the accuracy and reliability of the supplied historical data. All Quantitative Models rely on correct market data inputs. If incorrect market data is entered into even a well-founded model, the resulting information will be incorrect. However, even if market data is input correctly, Quantitative Model prices will often differ substantially from market prices, especially for instruments with complex characteristics, such as derivative instruments. See Item 4. Advisory Services for further information about Quantitative Model risks.  Reliance on Key Persons: Clients are substantially dependent on the services of the Principal and the Portfolio Managers. In the event of the death, disability, departure or insolvency of the Principal and Portfolio Managers or the complete transfer of his interest in the Adviser, the management of Clients can be adversely affected.  Sectors: To the extent the Tactical Strategies invest more heavily in particular sectors of the economy, performance will be especially sensitive to developments that significantly affect those sectors. The strategy can invest a significant portion of its assets in certain sectors and, therefore, the performance of the strategy can be negatively impacted by events affecting each sectors.  Sector Rotation Strategy: The Sector Rotation strategy uses a variety of market indicators to seek to identify the industries, sectors, or asset classes that are likely to outperform during a given quarter. Such indicators are evaluated on a quarterly basis and can be unable to predict events or conditions that arise during a quarter and lead the previously-selected industries, sectors, or asset classes to underperform other industries, sectors, or asset classes over the entire quarter. Additionally, the strategy relies on macroeconomic indicators to identify significant downturns in the market, and such indicators can fail to correctly or timely identify such downturns. In such event, the strategy can continue to be exposed to Underlying Investments that can lose significant value during downturns. There can be no guarantee that the Sector Rotation strategy will correctly or timely identify the industries, sectors, or asset classes that will outperform during a given quarter.  Sociopoli(cid:415)cal Risks: Natural disasters (e.g., earthquakes or weather), acts of war, terrorism and armed conflicts can nega(cid:415)vely impact por(cid:414)olio and asset values.  Trend-Based Strategy: The trend-based strategies (Trend, Trend Plus, and Trend X) use a variety of market indicators and stop levels to seek to identify upward or downward trends in the U.S. equity markets. To the extent such indicators or stop levels fail to give timely notice of a downward trending market, the strategies can continue to be exposed to Underlying Investments that can lose significant value during such downward periods. Similarly, if the indicators fail to timely identify a reversal of a downward trending market, the strategies can continue to be exposed to defensive ETFs at a time when there is significant appreciation in the equity markets. Either scenario can result in the strategy underperforming other strategies that do not employ a trend- based strategy, and there can be no guarantee that the trend-based strategies will correctly or timely identify market trends. Additionally, the Trend X strategy uses leveraged ETFs and the use of leverage in a strategy will increase volatility and can exacerbate the movements of the account values in both directions up and down, depending on market movements. Page 19 of 28  Item 9 Disciplinary Informa(cid:415)on On September 11, 2023, the SEC offered, and MSCM agreed to accept, a se(cid:425)lement rela(cid:415)ng to alleged viola(cid:415)ons of Sec(cid:415)on 206(4) of the Advisers Act and Rule 206(4)-1(d) thereunder. The SEC alleged that MSCM adver(cid:415)sed hypothe(cid:415)cal performance on MSCM’s public website without adop(cid:415)ng and implemen(cid:415)ng policies and procedures reasonably designed to ensure that hypothe(cid:415)cal performance was relevant to the likely financial situa(cid:415)on and investment objec(cid:415)ves of the intended audience. As part of MSCM’s se(cid:425)lement with the SEC, MSCM, without admi(cid:427)ng or denying the SEC’s findings, agreed to pay a civil monetary penalty and evaluate, update, and review MSCM’s applicable policies and procedures concerning adver(cid:415)sements that include hypothe(cid:415)cal performance. MSCM also proac(cid:415)vely engaged a new compliance consultant to conduct an independent compliance program review and provide ongoing consul(cid:415)ng support to ensure that MSCM is in full compliance with regulatory requirements. Item 10 Other Financial Industry Ac(cid:415)vi(cid:415)es and Affilia(cid:415)ons A. Broker-Dealer Registra(cid:415)on Neither MSCM nor the Principal is registered as broker-dealer or registered representa(cid:415)ve of a broker- dealer, nor do they have any pending applica(cid:415)on to register. B. Futures and Commodi(cid:415)es Registra(cid:415)on Neither MSCM nor the Principal is registered as a futures commission merchant, commodity pool operator, commodity trading advisor, or associated party of any of those, nor do they have any pending applica(cid:415)on to register as such. C. Affiliates MSCM is affiliated with Elkhorn Capital Partners, LLC (“Elkhorn”), a sponsor and manager of real estate investments that is neither registered nor required to register as an investment adviser. Elkhorn is wholly owned by the Principal and provides services to certain accredited investors. Although Elkhorn is in the business of inves(cid:415)ng in real estate and MSCM is in the business of inves(cid:415)ng in securi(cid:415)es, certain conflicts can arise between Elkhorn and MSCM concerning the alloca(cid:415)on of (cid:415)me and effort on the part certain Supervised Persons between Elkhorn and MSCM. The Principal has a material financial interest in Elkhorn and dedicates a significant por(cid:415)on of his business (cid:415)me to Elkhorn. Certain other Supervised Persons are involved in the opera(cid:415)ons of Elkhorn to a limited extent. The Principal ensures that appropriate resources are dedicated to MSCM at all (cid:415)mes. Clients can poten(cid:415)ally invest in real estate partnerships sponsored by Elkhorn, however, neither MSCM nor any of its Supervised Persons ac(cid:415)vely solicit or refer Clients to invest in Elkhorn. Certain Supervised Persons independently offer insurance advice that is not supervised by MSCM, in addi(cid:415)on to providing advisory services to Clients. While not supervised by MSCM, insurance advice provided to Clients are required to receive prior approval from MSCM Compliance to determine that such ac(cid:415)vity is appropriate to be offered to a Client. Page 20 of 28  D. Conflicts of Interest MSCM is not compensated for recommending or selec(cid:415)ng other investment advisers for its Clients. MSCM also has no other business rela(cid:415)onships with any investment advisers that create material conflict of interest other than the conflicts of interest discussed above with respect to MSCM serving as sub-adviser to the Fund. Other conflicts of interest have been discussed throughout the Brochure, including disclosure in Item 5 that MSCM receives management fees from variable insurance vehicle issuers that MSCM, in turn, passes through to the investment adviser representa(cid:415)ve recommending the variable insurance vehicle to the Client. Informa(cid:415)on regarding variable insurance vehicle issuers is provided to Clients who receive services to which the disclosure relates. Item 11 Code of Ethics, Par(cid:415)cipa(cid:415)on or Interest in Client Transac(cid:415)ons and Personal Trading A. Code of Ethics and Personal Trading Policy MSCM has adopted a code of ethics and personal trading policy (“Code of Ethics”) that complies with Rule 204A-1 under the Advisers Act and applies to all of its Supervised Persons. MSCM prohibits our Supervised Persons from using or a(cid:425)emp(cid:415)ng to use their posi(cid:415)on at MSCM to obtain improper benefits for themselves or any other person. MSCM’s Code of Ethics permits its Supervised Persons to invest for their personal accounts, subject to certain guidelines and restric(cid:415)ons. Personal securi(cid:415)es transac(cid:415)ons by Supervised Persons must be conducted in accordance with the requirements of MSCM’s Code of Ethics. Among other things, MSCM’s policies require that certain personal securi(cid:415)es transac(cid:415)ons by Supervised Persons be approved in advance by MSCM’s compliance department, as required under the Advisers Act. Supervised Persons must report certain personal securi(cid:415)es holdings upon employment and periodically therea(cid:332)er. MSCM’s Code of Ethics prohibits Supervised Persons from trading while in possession of informa(cid:415)on concerning trades for Clients, also called “front-running.” MSCM has also adopted policies and procedures designed to prevent Supervised Persons from being unduly influenced in their decisions by receipt of gi(cid:332)s, business entertainment or other inducements by third par(cid:415)es (e.g., as trading counterpar(cid:415)es, vendors or investors). MSCM will provide a copy of its Code of Ethics to Clients or prospec(cid:415)ve Clients upon request. B. Affiliated and Outside Business Ac(cid:415)vi(cid:415)es MSCM Supervised Persons are required to disclose any outside business ac(cid:415)vi(cid:415)es that can create a poten(cid:415)al conflict of interest between the Supervised Person’s interests and those of Clients. Reasonable controls, mi(cid:415)gants and disclosures are developed to address poten(cid:415)al and actual conflicts of interest. C. Par(cid:415)cipa(cid:415)on or Interest in Client Transac(cid:415)ons and Personal Trading By reason of MSCM’s or its Supervised Persons’ business or investment ac(cid:415)vi(cid:415)es, Supervised Persons acquire confiden(cid:415)al informa(cid:415)on, and, in such event, MSCM and the Supervised Persons are restricted, as appropriate, from ac(cid:415)ng upon such confiden(cid:415)al informa(cid:415)on for personal gain. Subject to MSCM’s Code of Ethics, Supervised Persons are permi(cid:425)ed trade for their own accounts in securi(cid:415)es that are recommended to and/or purchased for Clients. The Code of Ethics is designed to assure that the personal securi(cid:415)es transac(cid:415)ons, ac(cid:415)vi(cid:415)es and interests of our Supervised Persons will not interfere with (1) making Page 21 of 28  decisions in the best interest of Clients and (2) implemen(cid:415)ng such decisions while, at the same (cid:415)me, allowing Supervised Persons to invest for their own accounts. Item 12 Brokerage Prac(cid:415)ces A. Selec(cid:415)ng and Recommending Broker-Dealers MSCM is generally authorized to make the following determina(cid:415)ons in accordance with each Separately Managed Accounts’ objec(cid:415)ves and restric(cid:415)ons without obtaining prior consent from the Client: (1) which securi(cid:415)es or instruments to buy or sell and (2) the total amount of securi(cid:415)es or instruments to buy or sell. MSCM typically recommends to Separately Managed Accounts that they establish their securi(cid:415)es account(s) with Charles Schwab (“Schwab”) or Raymond James & Associates, Inc. (“RJA” and collec(cid:415)vely “Custodians”), members of the New York Stock Exchange and the Securi(cid:415)es Investor Protec(cid:415)on Corpora(cid:415)on (“SIPC”). In selec(cid:415)ng their Custodian, Clients are authorizing the Custodian’s affiliated broker- dealers to execute trades as the custodial arrangement does not permit MSCM to trade with other broker- dealers. MSCM recommends these Custodians based on reputa(cid:415)on, financial strength and stability, and the efficiency of execu(cid:415)on provided by their affiliated broker-dealers. MSCM believes that using a broker dealer affiliated with these Custodians allows for MSCM to achieve best execu(cid:415)on for its Clients, but there is no guarantee that this results in the lowest cost. MSCM generally considers a number of factors, including, for example, net price, reputa(cid:415)on, financial strength and stability, efficiency of execu(cid:415)on and error resolu(cid:415)on, block trading and block posi(cid:415)oning capabili(cid:415)es, willingness to execute related or unrelated difficult transac(cid:415)ons in the future and other ma(cid:425)ers involved in the receipt of brokerage services generally other than lowest cost. MSCM is not affiliated with the Custodians. The Custodians offer various services to MSCM, which include custody of securi(cid:415)es, trade execu(cid:415)on and clearance and se(cid:425)lement of transac(cid:415)ons. MSCM receives some benefits from the Custodians, which benefits MSCM and some or all Clients of MSCM. MSCM has an incen(cid:415)ve to recommend these Custodians due to the services they provide MSCM. 1. Research and Other So(cid:332) Dollar Benefits Custodians provide MSCM, without cost, so(cid:332)ware and support which allows MSCM to be(cid:425)er monitor and service Client accounts, including assistance with invoicing, trade execu(cid:415)on and recordkeeping. Custodians provide services to MSCM, including research, execu(cid:415)on, brokerage, custody and access to ETFs, mutual funds and other investments. Addi(cid:415)onally, other services provided assist MSCM in managing and administering Client accounts. These services are provided based in part on the assets held by the respec(cid:415)ve Custodians, and as such, create an incen(cid:415)ve for MSCM to direct Clients to their custodial pla(cid:414)orms. MSCM has an incen(cid:415)ve to recommend these Custodians due to the services they provide MSCM. Beyond those services, MSCM does not currently receive or an(cid:415)cipate receiving research or other so(cid:332) dollar benefits from brokers or third par(cid:415)es in connec(cid:415)on with Client securi(cid:415)es transac(cid:415)ons. To the extent MSCM receives other “so(cid:332) dollar” benefits, it will only do so within the Sec(cid:415)on 28(e) safe harbor provided by the Advisers Act. Page 22 of 28  2. Brokerage for Client Referrals MSCM does not receive Client referrals from broker dealers for which it executes client transac(cid:415)ons. Thus, MSCM does not have an incen(cid:415)ve to select or recommend a Custodian or broker dealer based upon its interest in receiving Client referrals. 3. Directed Brokerage MSCM and the Custodian account set up does not permit Clients to direct brokerage to a designated broker-dealer other than the Custodian’s affiliate broker-dealer. By selec(cid:415)ng the Custodian, the Client is direc(cid:415)ng its brokerage to the Custodian’s affiliate broker-dealer. By direc(cid:415)ng brokerage to the Custodian’s affiliate broker-dealer, MSCM is not in the posi(cid:415)on to nego(cid:415)ate brokerage commissions on behalf of Clients. Accordingly, Clients could pay more brokerage commissions as a result of MSCM not having the opportunity to nego(cid:415)ate brokerage commissions on the Client’s behalf. B. Aggrega(cid:415)on of Orders When possible, MSCM will aggregate the purchase or sale of securi(cid:415)es for various Clients at each Custodian. When trades are aggregated, the average execu(cid:415)on price will be applied to each par(cid:415)cipa(cid:415)ng Client account. Aggrega(cid:415)on should lead to lower transac(cid:415)onal costs, thereby saving the Clients money. Trades are not able to be aggregated across more than one Custodian and certain Clients, including Clients for which MSCM does not execute trades, are not included in aggregated trades. C. Trade Alloca(cid:415)on Prac(cid:415)ces The ETFs traded in the Tac(cid:415)cal Strategies are widely traded and not subject to price sensi(cid:415)vity. Accordingly, there is no need for MSCM to develop a trade alloca(cid:415)on rota(cid:415)on methodology. Accordingly, in placing orders for Clients for which it is responsible for trade execu(cid:415)on, communica(cid:415)ng changes in Model Por(cid:414)olios, and transmi(cid:427)ng trade orders to the Fund’s investment adviser there is no specified manner for communica(cid:415)on of the orders and changes. The Adviser periodically reviews its trade alloca(cid:415)on prac(cid:415)ces to ensure fairness to Clients. D. Trade Errors The Adviser and its investment adviser representatives must exercise prudence in making and implementing investment decisions on behalf of Clients. Errors can occur either in the investment decision- making process (e.g., a purchase of a security or an amount of security that violates a Client’s investment restrictions) or in the trading process (e.g., a buy order executed as a sell, the purchase or sale of a security other than what was intended, or trading an incorrect quantity of securities) (“Trade Errors”). Internal or clerical mistakes that affect the investment or trading process and have a financial impact to a Client will also be treated as Trade Errors. A Trade Error will generally be defined as a transaction that is executed in a manner that was not intentional and results in corrective action being taken. Any mistakes that do not affect the investment decision- making or trading process or cause a violation of a Client’s investment policies or restrictions, and do not cause gain or loss to the Client, will not be treated as Trade Errors. Quantitative Model errors are generally not Trade Errors. See Item 4 for additional information about Quantitative Model error risks. Broker dealers will generally be held responsible for a portion of any loss resulting from a Trade Error if the actions of such broker-dealer contributed to the error or the loss. Broker dealers will potentially assist the Page 23 of 28  Adviser in rectifying a Trade Error on favorable terms if their actions or inactions contributed to the Trade Error or the resulting loss. A broker-dealer will potentially absorb the loss from a Trade Error caused by the broker-dealer. However, we will not direct brokerage commissions to broker-dealers, or to enter into other reciprocal arrangements with broker-dealers, in order to induce a broker-dealer to absorb a loss from a Trade Error caused by the Adviser. Item 13 Review of Accounts A. Review of Clients The Supervised Person responsible for managing a Client will conduct reviews on a periodic basis to ensure that the account is being managed in alignment with the investment mandate. The Principal or another management person of the Adviser will periodically review the Clients for risk, performance, and suitability. B. Frequency of Review The Supervised Person responsible for managing a Client will generally conduct reviews on a quarterly basis. Oversight reviews are generally conducted on an annual basis. C. Content and Frequency of Regular Reports The Custodian of the accounts will provide the Clients with monthly unaudited performance informa(cid:415)on. Item 14 Client Referrals and Other Compensa(cid:415)on A. Other Compensa(cid:415)on No person, other than each Client, provides an economic benefit to MSCM in exchange for providing investment advice or other advisory services to such Client. B. Third-Party Solicitors At the (cid:415)me of upda(cid:415)ng this Brochure, MSCM has not entered into any agreements that provide for compensa(cid:415)on to be paid for referring Clients to MSCM. Item 15 Custody MSCM is deemed to have custody of Clients’ cash and securi(cid:415)es because MSCM is authorized to direct the Custodian of the account to withdraw funds to pay MSCM’s fees. All Client cash and securi(cid:415)es are maintained with a Custodian. MSCM par(cid:415)cipates in the Custodian pla(cid:414)orms and generally recommends to Clients that they establish their brokerage account(s) at broker dealers affiliated with the Custodian. Page 24 of 28  The designated assets of each Client shall be held by the Custodian pursuant to a custody agreement that is acceptable to the Client. The Custodian shall at all (cid:415)mes be responsible for the physical custody of the assets of the account; for the collec(cid:415)on of interest, dividends and other income a(cid:425)ributable to the assets of the account; and for the exercise of rights and tenders on assets of the account. Adviser shall not be responsible for any loss incurred by reason of any act or omission of the Custodian. Adviser issues such instruc(cid:415)ons to the Custodian as appropriate in connec(cid:415)on with the se(cid:425)lement of transac(cid:415)ons ini(cid:415)ated by Adviser. Clients will receive brokerage statements no less than quarterly from the Custodian. At all (cid:415)mes, we rely on the Custodian to value securi(cid:415)es and other assets held in Client accounts, including Custodian valua(cid:415)ons used for fee billing purposes, as we believe the securi(cid:415)es held in Client Accounts are most accurately valued by the Custodian. We are available to Custodians to provide addi(cid:415)onal input on fair valua(cid:415)on requests; however, we do not expect there to be fair valua(cid:415)ons for the types of securi(cid:415)es traded in Client accounts. Item 16 Investment Discre(cid:415)on Subject to any limita(cid:415)ons set forth in the IMA and only during the term of IMA, as designated by the Client, MSCM shall have full discre(cid:415)onary power and authority, without prior consulta(cid:415)on with or no(cid:415)fica(cid:415)on of Client, to buy, sell (including short sales), exchange, convert and otherwise trade in securi(cid:415)es of every kind and nature, including, without limita(cid:415)on, equi(cid:415)es, bonds, notes, debentures, trust receipts, financial futures contracts, over-the-counter deriva(cid:415)ve instruments, commodi(cid:415)es, commodi(cid:415)es futures, exchange traded funds, securi(cid:415)es of foreign issues (including American Depository Receipts) and other securi(cid:415)es of whatever kind or nature of any person, corpora(cid:415)on, government or en(cid:415)ty, whether readily marketable or not, and rights and op(cid:415)ons rela(cid:415)ng thereto, including put and call op(cid:415)ons wri(cid:425)en by the account or by others, on margin or otherwise, for such prices and on such terms as MSCM, in its sole discre(cid:415)on, deems advisable and in the best interests of Client. Client shall furnish Adviser with all addi(cid:415)onal powers of a(cid:425)orney and other documenta(cid:415)on, if any, necessary to appoint Adviser as agent and a(cid:425)orney-in-fact with respect to the account, but such powers shall not be construed to authorize Adviser to take any ac(cid:415)on not authorized by the IMA. Item 17 Vo(cid:415)ng Client Securi(cid:415)es MSCM does not have any authority to and does not vote proxies on behalf of Clients. Clients retain the responsibility for receiving and vo(cid:415)ng proxies for any and all securi(cid:415)es maintained in Client por(cid:414)olios. To this end, MSCM will instruct the Custodian to forward all proxy material directly to the Client. MSCM shall forward any proxy materials it receives that pertain to the assets in Client accounts to the respec(cid:415)ve Clients, or to the adviser(s) for an employee benefit plan covered by ERISA. Clients can contact MSCM at 214-922-9200 with any ques(cid:415)ons. Page 25 of 28  Item 18 Financial Informa(cid:415)on A. Prepayment of Fees MSCM does not require or solicit prepayment of more than $1,200 in fees per Client, six months or more in advance. B. Poten(cid:415)al Financial Impairment There is currently no financial condi(cid:415)on which is reasonably likely to impair MSCM’s ability to meet its contractual commitments or to provide advisory services to its Clients. C. Bankruptcy MSCM has never been the subject of a bankruptcy pe(cid:415)(cid:415)on. Page 26 of 28  Other Informa(cid:415)on - Privacy No(cid:415)ce What Does McElhenny Sheffield do with your Personal Informa(cid:415)on? Why? What? Social Security number and income How? Who? Financial companies choose how they share your personal informa(cid:415)on. Federal laws, and certain state privacy laws, give consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal informa(cid:415)on. Please read this no(cid:415)ce carefully to understand what we do. The types of personal informa(cid:415)on we collect and share depend on the product or service you have with us. This informa(cid:415)on can include:   Transac(cid:415)on or loss history and account transac(cid:415)ons  Assets and Investment Experience All financial companies need to share customers' personal informa(cid:415)on to run their everyday business. In the sec(cid:415)on below, we list the reasons financial companies can share their customers' personal informa(cid:415)on; the reasons we choose to share and whether you can limit this sharing. McElhenny Sheffield Capital Management is an SEC registered investment adviser. Registra(cid:415)on does not imply a certain level of skill or training.  To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. How we protect your personal informa(cid:415)on?  We train our employees to protect customer information.  We require independent contractors and outside companies who work with us to Why can't I limit all sharing? Other Important Informa(cid:415)on Ques(cid:415)ons? adhere to strict privacy standards through their contracts with us.  We continually seek to enhance our security tools and processes. Federal law gives you the right to limit: (1) sharing for affiliates’ everyday business purposes – informa(cid:415)on about your creditworthiness, (2) affiliates from using your informa(cid:415)on to market to you, and (3) sharing for nonaffiliates to market to you. We do not share informa(cid:415)on in a manner that you could limit. Accordingly, we are not required to offer and do not offer an opt-out. State laws and individual companies could poten(cid:415)ally give you addi(cid:415)onal rights. Your choice for a joint account will apply to everyone on your account unless you tell us otherwise.  California residents: We will not share informa(cid:415)on we collect about you with companies outside of McElhenny Sheffield Capital Management, unless the law allows. For example, we may share informa(cid:415)on with your consent or to service your accounts.  Vermont residents: If your account has a Vermont billing address, we will automa(cid:415)cally treat your account as if you have directed us not to share informa(cid:415)on about your creditworthiness with our Affiliates. Call (214) 922-9200 or email: info@mscm.net Page 27 of 28  Reasons we can share your personal informa(cid:415)on Do we share? Can you limit this sharing? Yes No For our everyday business purposes - such as to process your transac(cid:415)ons, maintain your account, respond to court orders, regulatory examina(cid:415)ons, and legal inves(cid:415)ga(cid:415)ons, or report to credit bureaus Yes No For our marke(cid:415)ng purposes - to offer our products and services to you For joint marke(cid:415)ng with other financial companies Yes No Yes No For our affiliates’ everyday business purposes— informa(cid:415)on about your transac(cid:415)ons and experiences No For our affiliates’ everyday business purposes— informa(cid:415)on about your creditworthiness We don’t share For nonaffiliates to market to you No We don’t share Page 28 of 28