PENCE Growth SMA

The composite Benchmark is currently 80% S&P 500 Index TR, and 20% Barclays Aggregate Total Return, rebalanced monthly. This has been the Benchmark for this composite since inception. The S&P 500 Index is a market capitalization weighted index that is designed to measure the equity market performance of United States companies. The Barclays Aggregate Total Return Index is a market cap weighted index measuring the aggregate performance of the U.S. investment grade bond market. Securities in this composite have a focus towards Large Cap Growth with approximately 25-35 equity holdings. Standard allocations in this composite are generally up to 80% equity and up to 20% fixed income. During periods of volatility higher cash positions may be held to limit downside. Equities selected for the composite typically focus on higher earnings growth and/or sales growth over a 3-5-year investment horizon. We may utilize all equity sector and/or country ETFs or Mutual Funds. Fixed income selections for the composite are typically in the form of an ETF and/or Mutual Fund, varying in duration and credit quality profile depending on market conditions. The Composite includes all wrap accounts managed to the strategy for each period presented. There is no minimum asset level required for inclusion in this composite nor are there any cash flow restrictions which would require the removal of an account from the composite.

The composite creation and implementation date is 9/01/2018.

The Composite includes all wrap accounts managed to the strategy for each period presented. There is no minimum asset level required for inclusion in this composite nor are there any cash flow restrictions which would require the removal of an account from the composite.

Pence, defined as Pence Capital Management and Pence Wealth Management, claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. Pence has been independently verified for the periods July 1, 2014 through December 31, 2019. The verification report is available upon request.

A firm that claims compliance with the GIPS standards must establish policies and procedures for complying with all the applicable requirements of the GIPS standards. Verification provides assurance on whether the firm’s policies and procedures related to composite and pooled fund maintenance, as well as the calculation, presentation, and distribution of performance, have been designed in compliance with the GIPS standards and have been implemented on a firm-wide basis. Verification does not provide assurance on the accuracy of any specific performance report. GIPS® is a registered trademark of CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein.

The firm is defined to include Pence Capital Management and Pence Wealth Management. Both are registered Investment Advisers in the State of California. Both entities are owned by the same individuals and share the same Chief Investment Officer and Investment Team. As such, they provide financial advice and consultation to individuals based on a fixed or hourly fee basis. They also provide investment management services on a wrap fee basis in accordance with the Registrant’s investment management wrap fee program. The Firm is defined to include assets managed across all its offices and includes both institutional, sub-advisory, and retail lines of business. The firm’s list of composite descriptions is available upon request.

Pence Capital Management, LLC (“PCM”) is an investment adviser registered with the State of California that provides institutional level portfolio consultancy services to certain Unit Investment Trust (UIT) product sponsors, as well as, asset management model development offered through LPL Financial, LLC’s (“LPL Financial”) Manager Select program. PCM’s Chief Investment Officer is Dryden Pence. Dryden Pence is also a registered representative and investment adviser representative of LPL Financial, member FINRA/SIPC and a registered investment adviser. PCM is not affiliated with LPL Financial.

Pence Wealth Management (“PWM”) is a financial services practice within LPL Financial, LLC (“LPL Financial”) comprised of multiple financial professionals that provide a series of services including personal investment advisory, third party managed advisory and brokerage services. Pence Wealth Management, Inc. is an investment adviser registered with the State of California to provide financial planning services. The financial professionals affiliated with PWM are registered with and offer securities and investment advisory services through LPL Financial, member FINRA/SIPC and a registered investment adviser.

Composite Performance does not reflect any taxes an investor may incur as a result of capital gains, interest, and income. Withholding taxes may vary according to the investor’s domicile and capital gain exposure. Past performance is not indicative of future results.

Net performance uses the maximum total wrap fee of 3%. The total wrap fee includes all charges for trading costs, portfolio management, custody and other administrative fees. Actual investment advisory fees incurred by clients may vary. Net of fee performance is calculated by reducing the “pure” gross of fee returns by a model fee, applied monthly, representing the maximum total wrap fee.

The U.S. Dollar is the currency used to express performance. Returns reflected the reinvestment of income and other earnings.

The annual composite dispersion presented is equal-weighted standard deviation calculated for the accounts in the composite the entire year. All presented risk metrics are calculated using gross-of-fee performance. For the SMA Composites “pure” gross-of-fee-performance is used. Policies for valuing investments, calculating performance, and preparing compliant presentations are available upon request.

Past performance does not guarantee future results. Different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by Pence Capital), will be profitable or equal any historical performance level. All investment strategies have the potential for profit or loss. Investment strategies such as asset allocation, diversification, and rebalancing do not assure or guarantee better performance and cannot eliminate the risk of investment losses. There is no guarantee that a portfolio employing these or any other strategy will outperform a portfolio that does not engage in such strategies. Any target referenced on this document is not a prediction or projection of actual investment results and there can be no assurance that any target will be achieved. Changes in investment strategies, contributions or withdrawals may materially alter the performance of an individual’s portfolio. Economic factors, market conditions, and investment strategies will affect the performance of any portfolio and there are no assurances that it will match or outperform any particular benchmark. Projections, forecasts and estimates referenced on the document are not purely historical in nature and are therefore necessarily speculative and subject to material variation.

Any index performance data appearing or referenced (directly or indirectly) herein has been compiled by the respective copyright holders, trademark holders, or publication/distribution right owners of each index. The indexes generally do not reflect the deduction of transaction and/or custodial charges, or the deduction of an investment-management fee, which would decrease historical performance results. Investors cannot invest directly in an index. Pence Capital makes no warranty, express or implied, for any decision taken by any party in reliance upon such index information.

Except as prohibited by law, and as a condition precedent to accessing this document, each investor agrees to release and hold harmless Pence Capital its members, managers, officers, directors, owners, employees, agents, and affiliates from any and all adverse consequences resulting from any actions or omissions related to this document that are independent of receiving personalized individual advice from Pence Capital. The preceding sentence shall not limit or waive any applicable investor rights under federal or state law, including securities laws and fiduciary obligations that cannot be limited or waived.