Sargent Investment Group

SARGENT I N V E S T M E N T G R O U P Sargent Investment Group, LLC Form ADV Part 2A Disclosure Brochure 4920 Elm Street, Suite 305 Bethesda, MD 20814 202-580-6400 https://sargentinvestmentgroup.com May 26, 2026 Our Form ADV, Part 2A (“Disclosure Brochure”) as required by the Investment Advisers Act of 1940 (the “Advisers Act”) is a very important document between our Clients and Sargent Investment Group, LLC (“SIG” or, the “Advisor”). This Disclosure Brochure provides information about the qualifications and business practices of our Advisor. If you have any questions about the contents of this Disclosure Brochure, please contact us by telephone at (202) 580-6400 or by email at compliance@sargentinvestmentgroup.com. SIG is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Registration of an investment advisor does not imply any level of skill or training. The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about SIG is available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our IARD # 297499. 1  Item 2 – Material Changes The following material changes have been made to this Disclosure Brochure since the last annual amendment filing on February 13, 2026:  There have been no material changes in the Disclosure Brochure. Item 3 – Table of Contents ITEM 2 – MATERIAL CHANGES 2 ITEM 3 – TABLE OF CONTENTS 2 ITEM 4 – ADVISORY BUSINESS 3 ITEM 5 – FEES & COMPENSATION 6 ITEM 6 – PERFORMANCE-BASED FEES & SIDE BY SIDE MANAGEMENT 10 ITEM 7 – TYPES OF CLIENTS 10 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 10 ITEM 9 – DISCIPLINARY INFORMATION 15 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATES 15 ITEM 11 – CODE OF ETHICS 15 ITEM 12 – BROKERAGE PRACTICES 16 ITEM 13 – REVIEW OF ACCOUNTS 19 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION 20 ITEM 15 – CUSTODY 20 ITEM 16 – INVESTMENT DISCRETION 20 ITEM 17 – VOTING SECURITIES 21 ITEM 18 – FINANCIAL INFORMATION 21 2  Item 4 – Advisory Business Sargent Investment Group, LLC (“SIG” or “the Advisor”) is a limited liability company (“LLC”) organized in the State of Maryland and is registered as an investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor was founded in April 2018 and is primarily owned by Brian McGregor, Chris Rhyne and the 2024 Thayer McGregor Family Trust. The Advisor employs a consultative approach to investment management and financial planning. Investment Advisory Services SIG provides investment advisory services to individuals, trusts, estates, non-profit organizations, corporations, defined contribution plans, pooled investment vehicles, and other business entities (each a “Client”). SIG provides investment advisory services on a discretionary or non-discretionary basis, based on the individual needs of a Client. The specific services provided and the associated fees will be outlined in an Investment Advisory Agreement between the Client and the Advisor. Through personal exploratory conversations with a Client, SIG’s Investment Advisor Representatives (“Advisory Persons”) gather a Client’s information (which will include topics such as, financial objectives, goals, investment time horizon and any other unique Client needs) and define, in conjunction with the Client, a client profile and investment objective in order to determine an appropriate asset allocation and security selection best suited to that Client. SIG will confirm this agreed upon investment objective with the Client and will agree any other specific Client instructions or restrictions. SIG continues to monitor a Client’s goals and circumstances and, on an ongoing basis, manages and rebalances the Client portfolio, as appropriate, taking into account any tax or other investment sensitivities communicated by the Client. See more information related to SIG’s process to monitor Client goals and portfolios in Item 8, section Method of Analysis and Investment Strategies below. SIG’s wealth management process starts with investment management but will also consist of the coordination of a comprehensive range of integrated financial services to help a Client reach their financial goals. SIG does not provide tax, accounting or legal advice, and encourages Clients to consult with their tax, accounting and legal experts as appropriate. A review is conducted with Clients no less than annually. Clients will be responsible to advise SIG of any changes to their financial information, goals or other details that may impact the appropriateness of their portfolio allocation and investment objective. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or listed on an exchange. Most Client assets will be invested in readily marketable stocks (both foreign and domestic), corporate or municipal bonds, exchange-traded funds and notes, options and mutual funds. Where appropriate, investments will be in small capitalization stocks or private investments, which in some cases are less liquid than investments in larger companies. Clients can request advice from us regarding securities that are outside our typical strategy upon request. In certain instances, and as agreed between SIG and the Client, SIG will retain other types of investments from a Client’s legacy portfolio due to the fit with the overall portfolio strategy or for tax-related or other reasons as identified between the Advisor and the Client. When managing assets on a discretionary basis, SIG is authorized to execute all trades in a Client’s account without gaining a Client’s permission prior to trading. When SIG services Client accounts on a non- discretionary basis, all trades will be executed after gaining final approval of transactions from the Client. In certain instances, SIG will provide advice to Clients related to outside assets (“Held Away Assets”), where the Client retains all control of the account or retains control over trading authority. SIG has no discretion to trade a Client’s Held Away Assets and clients will need to execute any advice given on their own. SIG will not intentionally hold physical custody of Client assets. Client accounts, both discretionary and non-discretionary, will be held by an independent qualified custodian, except as noted below in Item 15 - Custody. Although SIG typically accepts clients with $ 2 million of investable assets or more, we accept clients of 3  smaller assignments depending on the client relationship, client service requirements and certain other circumstances. Wrap Fee Program SIG does not sponsor or place Clients into a Wrap Fee Program. Investment management services are provided directly by SIG. Selection of Independent Managers For certain clients for whom it is suitable, SIG will recommend that a portion of a client’s assets be invested with certain independent third-party money managers, including private funds, or unlisted separately managed accounts (“SMA’s”) (collectively known as “Independent Manager(s)”), the terms and conditions to be set forth in a separate written agreement and/or offering documents between the Client and the Independent Manager. Independent Managers typically specialize in a particular type of security or strategy. The management of the assets in a Client’s accounts by some Independent Managers is not specific to the Client’s needs when traded but is determined by the strategy selected. Other Independent Managers will select assets specific to the Clients’ individual needs. Certain private funds will operate as pooled investment vehicles that the Client owns a percentage share in. When an Independent Manager is recommended by SIG, the Advisor is responsible for due diligence of and ongoing monitoring of the Independent Manager. Item 8 further describes our Methods of Analysis, Investment Strategies and Risks of Loss related to these investments. Financial Planning, Consulting Services, Self-Directed Assets SIG will typically offer a variety of financial planning and consulting services to clients. Services are offered in several areas, depending on a Client’s financial needs, goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation. Financial planning services are available to all Clients, but a Client is not required to utilize the service. Financial planning services may encompass one or more areas of need, including, but not limited to, investment planning, retirement planning, estate and estate tax planning, charitable giving planning, educational funding planning, cash flow and asset/liability analysis, risk tolerance assessment, assessing insurance coverage and other areas that a Client and we may agree upon. We cannot stress enough the importance that a Client accurately and completely communicate to their Advisory Person and SIG the information needed to complete a financial plan or more thoroughly understand Client needs and define their investment objective. Our goal is to provide Clients with the most personalized and complete financial plan as possible, as we intend for Clients to use it as a blueprint of how best to reach their goals. So that a Client’s plan/investment objective remains accurate and up-to- date, it is very important that a Client continually update their Advisory Person and SIG with any changes to their financial situation, goals or investment time horizon. Clients may engage SIG on a consulting basis for the provision of any particular investment service or a variety of services as agreed upon between SIG and the Client. The services to be provided, as well as any related fees, will be outlined in an agreement between SIG and the Client. Clients may choose to designate certain assets held with the Custodian as “self-directed” (“Self-Directed Assets”) and not subject to SIG’s investment advisory services or advisory fees. Self-directed assets must be specifically identified by the Client and approved by the Advisor in writing. SIG will have no responsibility or fiduciary duty with respect to any self-directed assets. In certain circumstances, SIG will charge an administrative fee for trading or other reporting services provided around Self-Directed Assets. Any administrative fees would be agreed with the Client in writing. Retirement Account Considerations As part of SIG’s advisory services, in certain circumstances an Advisory Person will provide a Client with 4  recommendations and advice concerning their employer retirement plan or other qualified retirement account. In some instances, where appropriate, SIG will recommend that the Client withdraw the assets from their employer's retirement plan or other qualified retirement account and roll the assets over to an individual retirement account ("IRA") that the Advisor will manage, or SIG will respond to a request from a Client to accept assets withdrawn from an employers’ retirement plan or other client IRA for management, without providing advice. If the Client elects to roll the assets to an IRA under SIG’s management, SIG will charge the Client an asset-based fee as described in Item 5. SIG is a fiduciary under the Investment Advisors Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we may also be fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way SIG makes money creates some conflicts with our Client’s interests, so SIG operates under a special rule that requires us to act in our Client’s best interest and not put our interest ahead of yours.  As a fiduciary, SIG must meet a professional standard of care when making investment recommendations (give prudent advice);  SIG will never put our financial interests ahead of yours when making recommendations (give loyal advice);  We seek to avoid misleading statements about conflicts of interests, fees and investments;  We have implemented policies and procedures designed so that our advice is in your best interest;  We charge no more than is reasonable for our services; and provide Clients with important information about our fees and any conflicts of interest. A Client is under no obligation, contractually or otherwise, to complete a rollover after any discussions with SIG, and may have several other options other than rolling over the funds. Furthermore, if a Client does decide to rollover funds into an IRA, they are under no obligation to have their IRA assets managed by SIG. Clients should carefully assess the guidelines of their current retirement plan and the pros and cons of withdrawing funds from the plan into an IRA and discuss these with their Advisory Person. Retirement Plan Advisory Services SIG also provides retirement plan advisory services on behalf of retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services can include: Investment Policy Statement (“IPS”) Design and Monitoring Investment Oversight Services (ERISA 3(21))  Plan Participant Enrollment and Education Tracking    Benchmarking Services  Ongoing Investment Recommendation and Assistance These services are provided by SIG serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of SIG fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Private Fund Management Services 5  The Advisor also serves as an investment manager to pooled investment vehicles (each a “Private Fund” and collectively the “Private Funds”). These services are detailed in the offering documents for the Private Funds, which include as applicable, operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). The Advisor manages the Private Fund based on the investment objectives, policies and guidelines as set forth in the respective Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in the Private Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Private Fund and further acknowledges and accepts the various risk factors associated with such an investment. The Private Fund will offer two (2) classes of interest to investors: Class A Interests, and Class B Interests. Class A Interests will only be offered, as appropriate, to investment advisory Clients of SIG. Class B Interests will only be offered to third parties who are not advisory clients of SIG. Only Class B Limited Partners will be subject to a Private Fund investment management fee payable to SIG. Please see Item 5 for additional information. For more detailed information on investment objectives, policies and guidelines, please refer to the respective Private Fund’s Offering Documents. Fiduciary Statement As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any non-waivable rights you possess. Assets Under Management As of December 31, 2025 SIG managed approximately $1,165,082,546 in discretionary assets under management and $310,716,868 in non-discretionary assets under management. Total assets under management are approximately $1,475,799,414. Item 5 – Fees & Compensation Investment Advisory Fees The standard fees assessed for investment advisory services (the “Advisory Fee”) are charged by SIG based on a tiered fee schedule where the Client’s assets under management determine the Advisory Fee to be applied. All Advisory Fees are paid quarterly in advance of each calendar quarter. SIG’s maximum standard fee is 1%, except where the $2 million household minimum is waived. In circumstances where the minimum household assets under management is waived, the maximum fee charged is 1.25%. In determining the fee owed under the tiered or blended fee calculation, a rate will be defined for each tier of assets under management, and then the total dollar amount of the fee calculated for each tier will be added together to equal the total fee due to SIG. All advisory fees and household minimums are negotiable depending on the scope and complexity of the client’s situation, the services requested and other factors. SIG fees are not based on a share of capital gains in the Client’s accounts. SIG retains the right to amend the Advisory Fees charged with thirty (30) days written notice to individual Clients. 6  Both the description of services offered and the specific manner in which fees are charged by SIG are established in the Client’s written Investment Advisory Agreement. SIG will, under most circumstances, bill its annual investment management fees on a quarterly basis, in advance, based on the total value of the Client’s account at the custodian on the last trading day of the previous calendar quarter (trade date balances at quarter end–see description below). If the Investment Advisory Agreement is executed at any time other than the first day of a calendar quarter, SIG Advisory Fees will be applied on a pro rata basis for that calendar quarter, which means that the Advisory Fee is payable in proportion to the number of days in the calendar quarter for which one is a Client. SIG currently excludes cash balances from the assets under management balances used to calculate the Advisory Fee due. Cash equivalent money market funds and any other traded cash-like mutual funds or ETF’s will be included in the Advisory Fee calculation. Further, the value of securities held on margin will be included in the Advisory Fee calculation. Client month end statements may reflect only settled positions as of the last day of the month, depending on the custodian utilized. Unsettled transactions will be listed as activity in the statement at month end, even if it is not reflected in the balance. SIG’s billing systems reflect Client positions from the custodian as of trade date, and SIG’s quarterly Client fee calculation is based on the trade date balance at quarter-end. Most securities held in accounts managed by SIG will be independently valued by the Custodian or the private fund advisor. Some client accounts will hold investments that are not valued by the custodian or by a private fund manager, including—but not limited to—privately offered securities, limited partnership interests, promissory notes, non-traded interests, and other illiquid or hard-to-value assets (“Non-Custodian Valued Assets”). Because in some cases custodians and private fund managers do not provide pricing for these holdings, our firm must apply a reasonable, good-faith valuation methodology to determine their value for purposes of account reporting, advisory fee billing, internal performance measurement, and calculation of regulatory Assets Under Management (“AUM”). When a third-party valuation is not available, we may determine the value of a Non-Custodian Valued Asset using one or more of the following methods, as appropriate: Independent valuation reports, if provided  The most recent offering memorandum or subscription statement  The most recent financial statements provided by the issuer  Capital account statements from general partners when available   A good-faith estimate based on material, reasonably available information These valuations are inherently subjective and may differ significantly from the value at which the asset could be sold, redeemed, or realized in a current market transaction. Values may also differ from those assigned by another adviser, auditor, fund manager, or custodian. Because advisory fees and AUM are calculated based on asset values, our valuation of Non-Custodian Valued Assets may affect the advisory fees you pay. Where possible, we seek to use values provided directly by the issuer or fund manager; however, when such information is delayed, unavailable, or deemed unreliable, we will apply our good- faith valuation policies. If updated valuations are later received, they will be reflected on a forward- looking basis only and are not retroactively applied for fee billing. A potential conflict of interest exists because the firm has a financial incentive to assign higher values to assets that increase billed fees. To mitigate this conflict, the firm applies consistent valuation procedures, retains documentation supporting each valuation, and periodically reviews the valuation methodology. Clients may request a copy of our written valuation procedures at any time. Clients who invest in private or illiquid assets are responsible for providing the firm with timely and accurate information related to capital account balances, capital calls, distributions, or other valuation-related documents received from the issuer or fund manager. Valuations performed for advisory or regulatory reporting purposes do not represent a guarantee of realizable value and may differ materially from prices obtained upon sale, redemption, or liquidation. Advisory Fees are typically deducted from the Client’s custodial account. In rare circumstances, as agreed to by SIG, the Client can elect to pay Advisory Fees directly to SIG via check or other means. Existing Clients 7  will be billed for assets added to new accounts during a calendar quarter but are not billed for additions of assets to existing accounts within a calendar quarter. No adjustments will be made to fees paid for partial withdrawals after quarter end, or for appreciation or depreciation in a Client account within a billing period. Either the Advisor or its Clients may terminate advisory agreements for any reason with written notice. SIG will cease all advisory work on the Client’s account as of the date that assets are transferred out of Client accounts with SIG. If Client has notified SIG in writing of its intent to terminate their Investment Management Agreement with SIG, then absent a specific request to immediately stop managing Client’s assets, SIG will manage the account until the assets are transferred out. Any quarterly or other fees paid in-advance will be reimbursed back to the Client on a pro-rata basis, calculated from the termination date to the end of the current calendar quarter. Clients will pay Advisory Fees whether their account makes or loses money on investments. Advisory Fees and costs will reduce any amount of money a Client will make on their investments over time. When a Client’s account value grows, whether through deposits or an increase of asset value, SIG will earn more Advisory Fees. The Advisor, therefore, has an incentive to encourage Clients to increase assets in their accounts. As a registered investment advisor and a fiduciary, SIG has a duty to always act in good faith and to place Clients’ interest first and foremost. At SIG’s discretion, the Client may combine the account values of family members to determine the applicable Advisory Fee. Combining account values will increase the calculated asset total, which can result in the Client paying a reduced Advisory Fee based on the available breakpoints in their fee schedule. Investment Management, Financial Planning and Consulting Service Fees SIG provides investment management, financial planning or other consulting services for individuals, families and estates or companies, based upon a one-time flat fee or for a yearly flat fee. If a one-time flat fee is negotiated, the fee will be payable in full in advance for engagements lasting not more than six months. If a yearly flat fee is charged, it will be paid quarterly in advance in four installments. Payment terms will be outlined in the agreement between SIG and the Client. The Advisor’s fixed fees are predicated on the complexity and scope of services to be performed. ERISA SIG is a fiduciary under ERISA with respect to the investment management services described in the investment management agreement between SIG and the ERISA Plan Client. As such, SIG is subject to specific duties and obligations under ERISA and the Internal Revenue Code (the “IRC”) that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, SIG only charges fees for investment advice about products for which SIG and/or its affiliates do not receive any commission, 12b-1 fees or other forms of compensation. Fees Associated with Independent Managers Each Independent Manager (defined above as SMA or other unlisted or private fund managers) utilized by SIG for a Client’s account, where appropriate, will assess its own fee schedule or management expenses, which will be disclosed in advance in writing via agreements, fund offering documents and/or other subscription documents signed by the Client. Independent Managers (especially private equity or hedge funds) in some cases also charge additional performance-based fees, which will also be included in any Client agreements. The Independent Manager charges their fees separate from, and in addition to, SIG’s Advisory Fee described above. Most hedge funds or private equity funds will operate as pooled investment vehicles, whose underlying assets are not held with the Client’s Custodian. Certain pooled investment vehicles that do not maintain underlying positions at the Custodian are able to provide manual updates of client investment values to the Custodian’s platform, at periods throughout the year. If the pooled investment vehicle cannot report their updated values to the Custodian, then the manager or client will report those balances, as available, to SIG, who will manually update balances for use in their billing systems. SIG will utilize the most recent balance provided by the Independent Manager to the 8  Custodian or SIG, at the end of the quarter for the Advisory Fee calculation. Note that values provided by Independent Managers may be updated on a delayed basis (i.e., current month or quarter update may relate to the balance at the previous month or quarter due to the manual nature of valuations of some funds.) See more above about policies used for valuation where prices are not supplied by an outside manager and about private fund and alternative investment risks below in Item 8, Methods of Analysis, Investment Strategies and Risk of Loss. Important Note About Additional Fees In addition to advisory and underlying investment fees, Client accounts will also be subject to various custodial transaction or account administration fees, depending on the nature of services an d transactions in the account. These fees vary with each custodian. Additional fees can include a basis point charge on assets held at the custodian, brokerage commissions for some products, markups/markdowns, other transaction fees or taxes (including transfer or regulatory taxes), custodial service fees (including wire transfer and electronic funds fees), odd-lot differentials and interest charges on any margin borrowings or debit balances. In certain instances, SIG will elect to bear the cost of certain administrative fees related to sub-advised or alternative investments that are recorded on the Custodian’s platform. Mutual funds and exchange-traded funds (“ETFs”) also charge internal management/expense fees, which are disclosed in each fund’s prospectus. A Client may be able to invest in any of these products directly, but would not receive the services of SIG, which are designed, among other things, to assist the Client in determining which products are most appropriate for each Client, and to provide ongoing monitoring and rebalancing of Client accounts. Private Fund Management Services As Advisor to the Private Fund, SIG will not receive Private Fund management fees from Class A Limited Partners. The Private Fund will charge Class B Limited Partners an annual fee of 0.75%, payable to SIG for its management of the Private Fund. Class B Limited Partners are investors who do not currently have an Investment Management Agreement with SIG. In the event that a Class A Limited Partner’s advisory agreement with SIG is terminated, the remaining Class A Interests held by such Class A Partner at the time the Advisory Agreement is terminated will automatically be converted to Class B Interests and be subject to the management fee as described above. In certain instances, the fee amount earned by SIG from the Private Fund will be more or less than the Advisory Fee specified in the Client Advisory Agreement with SIG. This can pose a conflict as it may incentivize the Client to stay onboarded with SIG. The conflict of interest of the additional fee received by SIG is mitigated as an investment in the Private Fund is only made if it is determined such investments fit within a client’s objective and are in the best interest of the clients. The Advisor, in its sole discretion, can waive or reduce the management fee with respect to certain Limited Partners in the Private Fund without notice to, or consent of, any other Limited Partner. Investors should refer to the respective Private Fund’s Offering Documents for more detailed information on fees and compensation. The Management Fee shall be paid quarterly in advance on the first business day of each fiscal quarter and each Class B Limited Partner’s proportionate share of the Management Fee shall be deducted from such Class B Limited Partner’s Capital Account. The investment management agreement between the Advisor and the Private Fund will continue in effect until terminated. Investors should refer to the Offering Documents for more detailed information on fees and compensation and the withdrawal and termination process. Investors will incur certain fees or charges imposed by third parties, other than the Advisor, in connection with investments made in the Private Funds. Each Private Fund is responsible for paying its own expenses, which include but are not limited to legal, accounting, regulatory, and other expenses relating 9  to the formation and/or organization of the Private Fund. These expenses are borne by investors. In some cases, there will also be underlying fees and expenses, similar to those incurred by the Private Fund, on the third-party funds that the Private Fund invests in, including management fees and fees on performance. Each investor is responsible for their own expenses and out-of-pocket costs incurred in connection with the organization of, their admission to, and the maintenance of their interest in a Private Fund. Other Fees and Compensation SIG does not buy or sell securities and does not receive any compensation for securities transactions in any account, other than the investment advisory fees and the private fund fees noted above. Item 6 – Performance-Based Fees & Side by Side Management The Advisor does not charge performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a Client. SIG Advisory Fees are charged only as disclosed above in Item 5. Certain private investments incur performance-based fees and would be disclosed in any investment documentation that the Client would be required to sign. Item 7 – Types of Clients As described in Item 4, SIG offers investment advisory services described in this Disclosure Brochure to individuals, trusts, estates, non-profit organizations, pooled investment vehicles and corporations or other business entities. All advisory fees and household minimums (including the $2 million household minimum referenced in Item 5 above) are subject to negotiation. Private Fund Management Services The Private Funds require that all investors meet the definition of “accredited investors” and also require investors to be “qualified purchasers” within the meaning of Section 2(a)(51) of the Investment Company Act of 1940 Act. The Private Funds generally require a minimum investment in the amount of $100,000. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis & Investment Strategies SIG begins the investment process by defining a Client’s current situation and long-term investment goals. Some considerations used in determining the Client’s unique plan are: Investment time horizon  Goals and objectives  Current and anticipated income needs  Tax status  Cost basis of current holdings  Special needs  Risk tolerance   Financial/estate plan Once the Client’s individual situation and goals are determined, SIG will use this information to arrive at an appropriate risk target for their investments. SIG then designs a portfolio asset allocation that will best meet the Client’s needs and investment objectives. A Client’s specific investment objective will be defined and articulated in an investment risk category, ranging from capital preservation to growth. It is also possible that an individual Client may have varying investment objectives for different accounts. All Client objectives, goals and/or restrictions will be defined and documented when reviewing investment objectives with Clients. 10  SIG’s primary investment execution is through individual equity and fixed income securities, mutual funds and ETFs, which are combined into a customized, proprietary asset allocation for each Client, or through the use of a SIG model portfolio(s) that meets the Client’s investment objective. SIG may also incorporate alternative and third-party manager’s investments within the Client’s asset allocation. SIG utilizes third-party technology to estimate a numerical risk score for each investment objective category and to quantify a risk score for each Client’s portfolio. While SIG will seek to maintain a Client portfolio within a tolerance range of the Client’s investment objective category risk score, each Client has individual needs and circumstances (i.e., maintain higher cash positions, tax sensitivities, etc.). In consultation with Clients, SIG will in certain circumstances agree to not rebalance an individual portfolio to within a closer range of the risk objective score for a period of time in order to accommodate the specifics of the situation and will continue to monitor the Client’s positions and goals. In addition, due to market volatility or circumstances, SIG will in certain circumstances determine not to immediately rebalance certain model portfolios until more market certainty is known. For these reasons, client risk will in certain circumstances be maintained outside of the client’s stated risk objective at different points of time. Any mutual fund or other third-party manager included in a Client portfolio is selected based on a quantitative and qualitative research process. This process reviews the risk and performance characteristics of a manager’s process, resources, depth and experience of the management team, along with key qualitative elements of the manager. Elements of this review vary, and can include:  Performance relative to benchmarks  Performance relative to peers  Volatility characteristics  Correlation statistics  Risk-adjusted returns  Total returns after expenses  Depth of investment team  Evaluation of investment process  Analysis of infrastructure  Manager’s Investment Policies and any potential drift from those policies  Financial strength of the management and/or parent company A select group of third-party money managers are approved for use in Client accounts and are monitored on an ongoing basis to determine if they are meeting long-term expectations. Client portfolios will be customized to meet the needs of the individual Clients. In limited situations, SIG may use options to hedge market risk or generate income for Clients who qualify to use these strategies and have approved their use. Risk of Loss All investments in securities involve a risk of loss of principal (invested amount) and any profits that have not been realized (the securities that were not sold to “lock in” the profit), that Clients should be prepared to bear. Stock and bond markets fluctuate substantially over time and can also experience high levels of volatility in short time periods, due to tangible and intangible events. The risk for each particular Client will vary in accordance with the Client’s goals and objectives, guidelines, restrictions and risk tolerance. In addition, all of our Clients will encounter general market risks, including but not limited to:  Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds with lower rates will be less attractive, lowering the market value of the bond.  Market Risk: The price of a security or investment instrument may drop in reaction to outside events. This type of risk is caused by external factors independent of a security’s or company’s 11  particular circumstance.  Inflation Risk: The eroding of purchasing power of a dollar. When inflation exists, a dollar today will not buy as much as a dollar in the future.  Currency (Exchange Rate) Risk: Foreign investments are subject to the fluctuations in the value of the dollar against the currency of the investment’s home country.  Business Risk: Risks associated with a particular industry or company within an industry. For example, some industries experience wider fluctuations in demand and therefore price for their products and can therefore have a higher risk of losses compared to companies with a more predictable demand for their product. An individual company may have certain internal issues which cause its stock to fluctuate beyond other businesses in the same industry.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, the more people interested in a security, the more liquid it will be. Investments that are more standardized (i.e., Treasury Bills) may be more liquid than more structured products. Securities of small capitalization companies may be less liquid that large capitalization companies.  Economic Risk: The likelihood that conditions in the overall economy may affect an investment or a company’s prospects.  Political Risk: The risk an investment’s returns could suffer as a result of political changes or instability in a country. Investments will not always be profitable and could lose money over long and/or short periods of time. There are no assurances that our investment strategies will succeed, and we cannot give any guarantee that it will achieve the investment objectives established by a Client or that any Client will receive a return on its investment. Due to the dynamic nature of investments and markets, strategies could be subject to additional and different risk factors not described above.  Investments made in mutual funds, ETFs and individual equities will be subject to market, liquidity, currency, economic, political and business risks.  Closed-end funds typically use a high degree of leverage. They may be diversified or non- diversified. Risks associated with closed-end fund investments include liquidity risk, credit risk, volatility and the risk of magnified losses resulting from the use of leverage. Additionally, closed- end funds may trade below their net asset value.  Investments in small (including “micro-cap”) and mid-capitalization stocks (or mutual fund or ETF products that include those stocks) are often more volatile and less liquid than investments in larger companies due to the potential lower frequency and volume of trading.  Stocks that trade at less than $5.00 per share (i.e. Penny Stocks), that are not listed on a national securities exchange, or do not meet other trading venue, liquidity, asset, market capitalization, revenue or reporting requirements are usually highly illiquid, speculative and subject to more volatile price swings. These investments ARE NOT suitable for all investors. Penny stocks are more suitable for investors with a high tolerance for risk.  Securities of small, mid-cap and penny stock companies may be more difficult to sell quickly. In addition, these companies may lack the management experience, financial resources and product diversification of larger companies, making them more susceptible to market pressures and business failure, and can result in a loss of principal amounts invested. 12   Fixed income securities are subject to various risks, including principal fluctuation, interest rate risk, inflation risk and default risk.  Options trading may involve the use of margin (borrowing) and can involve a high degree of risk, leading to the possibility of losing the entire principal (premium) amount invested, sometimes more. Options on securities can also be subject to greater fluctuations in value than an investment in the underlying security.  American Depository Receipts (“ADR’s”) are typically issued by a US bank or trust company and represent ownership of shares in underlying foreign securities. ADR’s, as well as the direct investment in foreign securities, will be subject to all the same risks as any US investment but will also be subject to currency risks. If the value of the company’s home currency increases or falls relative to the US dollar, the ADR or share value will also be impacted.  Alternative investments, including real estate investments, hedge funds and private equity funds, are normally not registered under the Investment Company Act of 1940 and are therefore not subject to the regulatory requirements it imposes. An investment in a private fund involves risks not typically associated with traditional investment funds and can be illiquid due to restrictions on redemptions and transfers within a secondary market. They are generally offered through private placement which are available only to those investors that meet certain requirements. They can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial amount of their investment. Alternative investments may lack transparency and/or delayed valuation reporting, as to share price, valuation and portfolio holdings and may charge investors significant performance fees, as well as ongoing management fees and other expenses. Complex tax structures often result in delayed tax reporting beyond the April 15 standard tax filing date. Cash flows from an investment may not match the timing of required investor tax payments for any gains or income reported for the investment in a certain year. Trading may occur outside the United States which could pose greater risks than trading on US exchanges and in US markets. Historical results are not indicative of future returns.  Structured Notes risk - o Complexity. Structured notes are complex financial instruments. Clients should understand the reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may include leverage multiplied on the performance of the reference asset or index, protection from losses should the reference asset or index produce negative returns, and fees. Structured notes may have complicated payoff structures that can make it difficult for clients to accurately assess their value, risk and potential for growth through the term of the structured note. Determining the performance of each note can be complex and this calculation can vary significantly from note to note depending on the structure. Notes can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a structured note to fully understand how the payoff on a note will be calculated and discuss these issues with SIG. o Market risk. Some structured notes provide for the repayment of principal at maturity, which is often referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing financial institution. Many structured notes do not offer this feature. For structured notes that do not offer principal protection, the performance of the linked asset or index may cause clients to lose some, or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the structured note may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, and/or market volatility. 13  o Issuance price and note value. The price of a structured note at issuance will likely be higher than the fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated value of the structured note on the cover page of the offering prospectus, allowing investors to gauge the difference between the issuer’s estimated value of the note and the issuance price. The estimated value of the notes is likely lower than the issuance price of the note to investors because issuers include the costs for selling, structuring and/or hedging the exposure on the note in the initial price of their notes. After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value given their complexity. o Liquidity. The ability to trade or sell structured notes in a secondary market is often very limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on securities exchanges. As a result, the only potential buyer for a structured note may be the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date, or risk selling the note at a discount to its value at the time of sale. o Credit risk. Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated to make payments on the notes as promised. These promises, including any principal protection, are only as good as the financial health of the structured note issuer. If the structured note issuer defaults on these obligations, investors may lose some, or all, of the principal amount they invested in the structured notes as well as any other payments that may be due on the structured notes.  Margin and Lines of Credit - Clients who borrow against their investment account through use of margin or other lending agreements are subject to additional risks that may not be suitable for all investors. Margin agreements are typically with the custodian, while a line of credit may be with a bank affiliated with the custodian, or another custodian. Through margin/lending agreements Clients are pledging the securities in their account, the value of which is affected by market events outside their control, leading to a high degree of risk. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and as a result, the custodian/bank may take action, such as issuing a margin call (request for additional funds) or selling securities or other assets in your account(s) to satisfy margin requirements. Clients may not be entitled to choose which security is sold, which can cause Clients to suffer adverse tax consequences. An increase in interest rates will affect the cost of borrowing, and your custodian can change margin requirements at any time without notice. Clients should read any margin lending or loan documents carefully to ensure they fully understand the risks and consult with their tax advisors as necessary.  Cybersecurity - The computer systems, networks and devices used by SIG and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in 14  which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. The price of all investments can and will fluctuate and any individual security may lose all its value. Item 9 – Disciplinary Information SIG does not have any legal, financial or other “disciplinary” items that it is required to report. SIG is obligated to disclose any legal or disciplinary event that would be material to a Client when evaluating our advisory business or the integrity of our management. Item 10 – Other Financial Industry Activities and Affiliates SIG has in the past and may in the future receive incentives from third-party investment managers, whose products are used for SIG Client investments. Types of incentives can include, entertainment, meals (e.g., “lunch and learn”), or entry to investment conferences or other educational events, including reimbursement of reasonable travel and lodging costs to attend a conference. This raises a potential conflict of interest and incentive for SIG to invest in these products for Clients. SIG believes that the attendance at educational, conference or other events hosted by investment providers is not a conflict as attendance allows for more in-depth due diligence on portfolio managers and the products they provide, and to better understand investment choices available for Clients. All investment decisions made for Clients take into account the individual needs of each Client and follow the guidelines of our Code of Ethics Policy. Conferences and events attended by employees are monitored. SIG does not have any undisclosed relationship or arrangement that is material to their advisory business or to Clients. Item 11 – Code of Ethics In accordance with the Advisers Act, Rule 204A-1, SIG has adopted a Code of Ethics. This Code of Ethics outlines all employees who are deemed to be “access persons” and mandates their compliance with applicable regulations and federal laws. Additionally, these employees must engage in high ethical standards at all times, disclose all information and conflicts and place the Client's interest above their own. The Code of Ethics includes, but is not limited to, provisions relating to the confidentiality of Client information, a prohibition on insider trading, disclosure of outside activities, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons at the Advisor must acknowledge the terms of the Code of Ethics annually, or as amended. A copy of this Code of Ethics will be provided to any Client or prospective Client upon request. If SIG or its representatives offer any investment with which they have a conflict of interest, it must be disclosed in advance. SIG will provide a copy of its Code of Ethics upon request by Clients. In certain instances, SIG managing partners, officers or employees (“Supervised Persons”) trading in their own accounts or for related persons can create either actual or perceived conflicts of interest. As such, SIG has established the following restrictions:  A Supervised Person shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her affiliation with SIG or the custodian, unless the information is also generally available to the investing public on reasonable inquiry. No person shall prefer his or her own interest to that of the advisory Clients.  SIG and its employees generally may not participate in private placements without pre-clearance from the Advisor's Chief Compliance Officer (“CCO”). 15   SIG respects the right of Clients to specify investment objectives, guidelines, and conditions or restrictions on the overall management of their accounts.  Any individual not in observance of the above may be subject to termination. No Proprietary Investments SIG recommends that certain clients invest a portion of their assets in pooled investment vehicles that we manage. This is a conflict of interest; however, clients pay us only a single layer of advisory fees, either at the advisory client level (Advisory Fee) or at the fund level (Private Fund management fee), when making such investments. In addition, as a fiduciary, we are obligated to make recommendations we believe to be in the best interest of our clients. SIG does not offer any investments in which our Supervised Persons or any person related to us, have a partnership or act as a general partner of the investment company or fund. Furthermore, SIG does not offer any investments in which our Supervised Persons or any person related to us act as an investment advisor for the investment company. Personal Trading – Participation in Client Transactions Subject to satisfying the Code of Ethics policy and applicable laws, Supervised Persons of SIG are allowed to trade for their own accounts in securities or private funds/alternative investments which are recommended to, and/or purchased for our Clients at or around the same time we place trades for Clients. There is a possibility that Supervised Persons might benefit from market activity traded for a Client in a security that is also held by an employee. There may be differences in transactions made in employee accounts versus transactions made for Clients due to variations in personal goals, investment horizons, risk tolerance and liquidity needs. A SIG employee may be buying around the time a Client is selling, or vice versa, for any number of personal reasons such as managing concentrations or a need to raise capital, having nothing to do with the Advisor’s fundamental thesis on the investment. Employees may also invest in a security before it is necessarily appropriate for the Advisor to recommend it to Clients. All Supervised Persons are required to report all personal securities transactions. SIG seeks to disclose and avoid any actual or potential conflicts of interests or resolve such conflicts in the Client’s favor. Records will be maintained for all securities or products bought or sold by SIG and SIG Supervised Persons. The CCO or qualified representative of SIG reviews these records on a quarterly basis. As described more in Item 12 below, Trade Aggregation, SIG may trade or rebalance a security(s) across all accounts, which can include Supervised Person accounts also invested in those securities. Prices obtained for aggregated trades would be allocated to each account on an average price basis, according to our trading policies. Supervised Person trading is continually monitored to reasonably prevent conflicts of interest between SIG and its Clients. Item 12 – Brokerage Practices The custodian, who holds Client assets and provides trading and other services, is meant to safeguard Client assets and is engaged by the Client, who will then authorize SIG to place trades in the account with the custodian. SIG will recommend certain custodian(s) to Clients based on criteria such as: reasonableness of commissions/fees charged to the Client, services and technology made available to the Client and Advisor, reputation and financial health of the institution, execution capabilities, responsiveness to SIG and their Clients, etc. Clients are not obligated to use a custodian(s) recommended by SIG but SIG may be limited in the services it can provide if a recommended custodian is not engaged. SIG typically recommends the brokerage and custodial services of Goldman Sachs Custody Solutions (“GSCS” or the “Custodian”), which is the d/b/a for the legal entity Folio Investments, Inc. Folio Investments, Inc. is an SEC-registered broker-dealer and a member of FINRA/MSRB/SIPC. GSCS offers services to independent investment advisors, which include: custody of securities, trade execution, 16  clearance and settlement of transactions and technology. In exchange for using the services of SIG’s custodians, SIG will receive, without cost, computer software and related systems support that allows SIG to monitor and service its clients’ accounts maintained with SIG’s custodian(s). SIG’s custodian(s) also makes available to the Firm products and services that benefit the Firm but may not directly benefit the client or the client’s account. These products and services assist SIG in managing and administering client accounts. They include investment research, both SIG’s custodian(s)’s own and that of third parties. SIG may use this research to service all or some substantial number of client accounts, including accounts not maintained at SIG’s custodian(s). In addition to investment research, SIG’s custodian(s) also makes available software and other technology that:  provide access to client account data (such as duplicate trade confirmations and account statements);  facilitate trade execution and allocate aggregated trade orders for multiple client accounts;  provide pricing and other market data;  facilitate payment of our fees from our clients’ accounts; and  assist with back-office functions, recordkeeping, and client reporting. SIG’s custodian(s) also offers other services intended to help us manage and further develop our business enterprise. These services include:  educational conferences and events;  technology, compliance, legal, and business consulting;  publications and conferences on practice management and business succession; and  access to employee benefits providers, human capital consultants, and insurance providers. SIG’s custodian(s) at times could also provide the Firm with other benefits such as occasional business entertainment of Firm personnel. The benefits received by SIG through its participation in the SIG’s custodian(s) custodial platform do not depend on the amount of brokerage transactions directed to SIG’s custodian(s). In addition, there is no corresponding commitment made by SIG to SIG’s custodian(s) to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as a result of participation in the program. While as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that clients maintain their assets in accounts at SIG’s custodian(s) will be based in part on the benefit to SIG of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by SIG’s custodian(s). The receipt of these benefits creates a potential conflict of interest and could indirectly influence SIG’s choice of SIG’s custodian(s) for custody and brokerage services. SIG will periodically review its arrangements with the BD/Custodians and other broker-dealers against other possible arrangements in the marketplace as it strives to achieve best execution on behalf of its clients. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including, but not limited to, the following:  a broker-dealer’s trading expertise, including its ability to complete trades, execute and settle difficult trades, obtain liquidity to minimize market impact and accommodate unusual market conditions, maintain anonymity, and account for its trade errors and correct them in a satisfactory manner;  a broker-dealer’s infrastructure, including order-entry systems, adequate lines of communication, timely order execution reports, an efficient and accurate clearance and 17  settlement process, and capacity to accommodate unusual trading volume;  a broker-dealer’s ability to minimize total trading costs while maintaining its financial health, such as whether a broker-dealer can maintain and commit adequate capital when necessary to complete trades, respond during volatile market periods, and minimize the number of incomplete trades;  a broker-dealer’s ability to provide research and execution services, including advice as to the value or advisability of investing in or selling securities, analyses and reports concerning such matters as companies, industries, economic trends and political factors, or services incidental to executing securities trades, including clearance, settlement and custody; and  a broker-dealer’s ability to provide services to accommodate special transaction needs, such as the broker-dealer’s ability to execute and account for client-directed arrangements and soft dollar arrangements, participate in underwriting syndicates, and obtain initial public offering shares. SIG’s clients utilize qualified custodians other than SIG’s recommended custodian(s) for certain accounts and assets, particularly where clients have a previous relationship with such qualified custodians. Client Directed Brokerage Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage SIG to manage on a discretionary basis, SIG has full discretion with respect to securities transactions placed in the accounts. This discretion includes the authority, without prior notice to the client, to buy and sell securities for the client’s account and establish and affect securities transactions through the BD/Custodian of the client’s account or other broker-dealers selected by SIG. In selecting a broker-dealer to execute a client’s securities transactions, SIG seeks prompt execution of orders at favorable prices. A client, however, may instruct SIG to custody his/her account at a specific broker-dealer and/or direct some or all of his/her brokerage transactions to a specific broker-dealer. In directing brokerage transactions, a client should consider whether the commission expenses, execution, clearance, settlement capabilities, and custodian fees, if any, are comparable to those that would result if SIG exercised its discretion in selecting the broker-dealer to execute the transactions. Directing brokerage to a particular broker-dealer may involve the following disadvantages to a directed brokerage client:  SIG’s ability to negotiate commission rates and other terms on behalf of such clients could be impaired;  such clients could be denied the benefit of SIG’s experience in selecting broker-dealers that are able to efficiently execute difficult trades;  opportunities to obtain lower transaction costs and better prices by aggregating (batching) the client’s orders with orders for other clients could be limited; and  the client could receive less favorable prices on securities transactions if SIG were to place transaction orders for directed brokerage clients after placing batched transaction orders for other clients. Trade Errors SIG’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade error occurs, SIG endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at SIG’s custodian(s), or another BD, as the case may be. In the event an error is made in a client account custodied 18  elsewhere, SIG works directly with the broker in question to take corrective action. In all cases, SIG will take the appropriate measures to return the client’s account to its intended position. SIG believes that GSCS, provides quality execution services at competitive prices. Trading and Trade Aggregation Even within the same investment objective or model, Client accounts are managed independently to meet individual Client needs and restrictions. At times, an investment advisor may place similar trades in numerous accounts within a single day that are not aggregated. Investment advisors may also place trades in one or more accounts that are directly opposite of trades placed for other accounts. This can occur, for example, when different advisors are rebalancing the same security, or when one account needs to raise cash while a new account is funding. In certain cases, SIG will (but is not obligated to) combine or “batch” such orders in an effort to obtain best execution or to allocate equitably among its Clients differences in prices and any transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and transaction costs and will be allocated among our Clients in proportion to the purchase and sale orders placed for each Client account included in that particular trade. If an aggregated order is not completely filled, SIG will allocate the total securities that executed pro rata among the accounts participating in the order that day. In rebalancing any SIG managed model, SIG seeks to batch all trades made within a model in order to handle Clients equitably. In the event that a rebalance trade cannot be batched, SIG will randomize the order of any execution trades so that no individual Client takes preference over another Client. Discretionary and non-discretionary mutual fund trades will not have a separate execution for orders that are put into the system on the same day. As an investment manager to the Funds, the Advisor does not typically engage in active trading of publicly traded securities. When, on occasion, the Advisor or the Funds transact in publicly traded securities, the Advisor will seek to facilitate such transactions through the retention of broker-dealer/custodian for custody and execution services. Item 13 – Review of Accounts Client accounts and portfolios will be reviewed by SIG on a regular basis. Clients will be provided with written reports containing relevant account information and performance at least annually, and accounts will be rebalanced as required. Reviews are conducted by Investment Advisor Representatives of the Advisor. SIG also provides certain Clients with household summaries, statistical performance reports or other summary data of their managed accounts when deemed necessary or at the request of the Client. SIG relies on outside service providers to calculate this information and it is not independently verified. The information used in these reports is gathered from data provided by the custodian, but Clients should always rely on their official custodian statement as the official record of their account. Account or household information reports are not meant to impart legal, tax or accounting advice. Samples of accounts will periodically be reviewed by the CCO and/or designee for suitability. Clients will receive monthly or at least quarterly, statements from the custodian detailing all transactions made on their behalf, other than certain assets invested in any private fund. This statement will include all deposits, withdrawals, as well as entries showing the associated management fees and expenses charged/debited from the Client's accounts. These reports will show the current market values and transactions during the past month or quarter as well as interest, dividends and capital gains for the reporting period. These custodian statements are a Client’s official account records. Investors in a private fund will receive audited financial statements no less than annually, that will serve as the official record. 19  Certain private fund general partners will also provide investors with periodic, unaudited reports regarding the Private Fund’s holdings, allocations, and performance throughout the year. The investments made by the Private Funds are generally private, illiquid and long-term in nature. Accordingly, the review process is not directed toward a short-term decision to dispose of securities. However, the Advisor closely monitors companies/funds in which the Private Funds invest and periodically checks to confirm that each Private Fund is maintained in accordance with its stated objectives as outlined in the Offering Documents. Additional information regarding causes for reviews of the Private Fund is contained in the Private Fund’s prospectus and statement of additional Information. Item 14 – Client Referrals and Other Compensation Referral Arrangements SIG does not currently receive any compensation for Client referrals. At any time in the future, SIG may enter into a referral arrangement and elect to compensate certain third parties for such referrals. Clients whose accounts are the subject of such referral fees will receive disclosure of the terms of the referral arrangement as required by Rule 206(4)-1 under the Adviser’s Act. In no case would any referral payment reduce the value of an investment, reduce the assets in a Client account, or violate the terms of the SIG Code of Ethics. Item 15 – Custody All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to retain their funds and securities and direct SIG to utilize the custodian for the client’s securities transactions. SIG’s agreement with clients and/or the clients’ separate agreements with the B/D Custodian typically authorize SIG through such BD/Custodian to debit the clients’ accounts for the amount of SIG’s fee and to directly remit that fee to SIG in accordance with applicable custody rules. The BD/Custodian recommended by SIG has agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to SIG. SIG encourages clients to review the official statements provided by the custodian, and to compare such statements with any reports or other statements received from SIG. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices.” Certain Client Accounts invested with Private or other Independent Managers will hold Client assets with a qualified custodian, other than the Custodian with whom the Client has signed their brokerage account agreement with, or with an administrative entity that produces audited annual statements on the fund. Clients should be provided the name of the custodian/administrator and the nature and frequency of investment valuations, etc. in the client subscription documents or other agreements that will be signed by the Client when the investment is made or can request the information from SIG or the Independent Manager. Values from Private Funds or Alternative Managers will in some instances be fed into the Client’s SIG Custodian account statement for reporting, even though the assets are not held with that Custodian. Item 16 – Investment Discretion SIG manages money on a discretionary and non-discretionary basis. In most circumstances, Clients grant SIG complete discretion. Clients who open discretionary accounts are required to execute an Investment Advisory Agreement which, among other things, grants SIG and its Advisory Persons the authority to manage Client assets on a discretionary basis, meaning SIG and its Advisory Persons have the authority to select the identity and amount of securities to be bought or sold in the Clients’ account[s] without obtaining specific Client consent. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objective for the particular Client relationship. For non- discretionary accounts, SIG will contact the Client prior to executing any transaction. 20  Item 17 – Voting Securities All Clients of SIG will retain the responsibility for receiving and voting proxies for any and all securities maintained in Client portfolios. Proxies are mailed to each Client directly by the respective custodian. Should a client have questions regarding a particular proxy solicitation, they may contact SIG at the phone number listed on the cover of this Brochure. From time to time, securities held in the accounts of Clients may be the subject of class action lawsuits. SIG offers no legal services and therefore has no ability or obligation to determine if securities held by the Client are subject to a pending or resolved class action lawsuit. Where SIG receives written or electronic notice of a class action lawsuit, settlement or verdict affecting securities owned by a Client, it will forward all notices, proof of claim forms and other materials to the Client. Electronic mail is acceptable where appropriate when the Client has authorized contact in this manner. Private Fund Management Servies SIG will vote proxies for Securities held by the Private Fund to the extent applicable. SIG has adopted proxy voting policies, procedures, and guidelines designed to vote proxies efficiently and in the best interest of the Securities held by the Private Fund. SIG seeks to identify any material conflicts of interest and to ensure that such conflicts do not interfere with voting in the Funds’ best interest. SIG general votes along with management but in certain instances, SIG may choose to vote contrary to management. SIG will review internally with the Fund to vote and record-keep the Fund’s proxy ballots. Copies of SIG’s proxy voting policies and information about how SIG voted a Fund’s proxies by contacting the firm. The Advisor is authorized and directed to instruct the Private Fund to forward promptly to the Advisor copies of all proxies and shareholder communications relating to Securities held. The Private Fund agrees that the Advisor will not be responsible or liable for failing to vote any proxies or addressing related shareholder communications on a timely basis. Item 18 – Financial Information Registered investment advisors are required in this Item to provide Clients and prospective Clients with certain financial information or disclosures about their firm’s financial condition. SIG has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding. 21