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Disclosures  

Your adviser may have arrangements with certain third-party service providers such as Custodians, whereby Adviser may receive a portion of the fees received by such third-party service providers from clients introduced to the third party by adviser.

Loring Ward is a party to written agreements with certain investment advisers, including various independent and affiliated investment advisers, pursuant to which Loring Ward pays certain investment advisers who refer clients to Loring Ward compensation equal to a percentage of the investment advisory fees received by Loring Ward from clients introduced to Loring Ward by those investment advisers. In most cases, the referral fees are paid at the rate of fifty percent (50%) of the investment advisory fee charged by Loring Ward. Referring Advisers may also have personal accounts with Loring Ward, for which Loring Ward provides service free of charge.

LWI Financial Inc. may recommend that clients establish brokerage accounts with certain registered broker-dealers ("Custodians") to maintain custody of clients' assets and to effect trades for their accounts. These Custodians provide LWI Financial Inc. with access to their institutional trading and custody services, which are typically not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a minimum dollar amount of the advisor's clients' assets are maintained in the Custodian's accounts and is not otherwise contingent upon committing any specific amount of business or trading. Such Custodian services include brokerage, custody, research and access to investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. The Custodian may also allow all or a portion of trading costs, if any, to a Broker-dealer affiliated with your Advisor.

The Custodians make available to LWI Financial Inc. other products and services that benefit LWI Financial Inc. but may not benefit its clients' accounts. Some of these other products and services assist LWI Financial Inc. in managing and administering clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements); facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts); facilitate payment of LWI Financials fees from its clients' accounts; and assist with certain back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of LWI Financials accounts.

From time to time, LWI Financial Inc. may extend a loan to an investment adviser representative or registered investment adviser. LWI Financial Inc. may also provide or assist in the payment for client or educational resources for those advisors who have a greater number of clients or investments referred to LWI Financial Inc.. LWI Financial Inc. may also pay certain independent and affiliated investment advisers (including Loring Ward Investment Advisor Representatives, ("IARs")) an administrative and service fee for certain shareholder services provided by the relevant investment advisers in connection with educating and assisting certain clients who purchase shares of the SA Funds. LWI Financial Inc. may provide other services intended to assist and develop advisor's businesses, including consulting, publications, and conferences on practice management, information technology, marketing and regulatory compliance. Those services may be provided directly or through third-parties at cost or on a discounted price. As such a conflict of interest may arise in advisors who select services from LWI Financial Inc. based upon reasons other than services provided directly to the client.

LWI Financial Inc. sponsors due diligence and educational seminars for selected independent and affiliated investment advisers Invitations are issued at LWI Financial Inc.'s discretion. Such special educational sessions provide an opportunity to introduce leading investment advisers to one another, to solicit ideas from the participants about sales and marketing opportunities, and to provide advanced technical and sales education. These learning opportunities are sponsored and may be paid for by LWI Financial Inc. at no additional cost to LWI Financial Inc.'s clients. LWI Financial Inc. may pay for all or a part of the travel and other expenses of each selected investment adviser associated with attendance at such due diligence and training seminars.

LWI Financial Inc. may have arrangements with certain independent and affiliated investment advisers (including LWI Financial Inc.'s IARs) in which LWI Financial Inc. agrees to reimburse the advisers a portion, or all of the expenses associated with the advisers sponsoring educational seminars for clients and/or potential clients.

In recognition of the supervisory responsibilities broker-dealers have with regard to their registered representatives, LWI Financial Inc. has signed agreements with various broker-dealers stating the terms under which those broker-dealers authorize their registered representatives to refer potential investors to LWI Financial Inc.. In most cases, these agreements provide for the payment of all fees pertaining to LWI Financial Inc. accounts directly to the cooperating broker-dealers. In addition, LWI Financial Inc. normally pays such broker-dealers up to ten percent of the advisory fees it collects from investors referred by those broker-dealers' registered representatives for the Synervest Asset Management program. This payment is intended to compensate the broker-dealers for their supervisory efforts; it is not part of the referral fee. LWI Financial Inc. may pay broker-dealers additional compensation to participate in selected marketing programs.

Order Routing Disclosure
SEC Rule 606
Loring Ward Securities Inc. is an introducing broker-dealer and FINRA member firm that clears its transactions through Pershing LLC. Pershing LLC has provided the data concerning the routing of order flow (the "Data") on the order routing disclosure web site. Although Pershing LLC has used commercially reasonable efforts to provide accurate data, the data is provided to you on an "as is" basis.

If you would like to read this information, visit the order routing disclosure site and enter Loring Ward Securities Inc when prompted for the broker-dealer's full name.

Additional information is available elsewhere on this web site or may be obtained by calling, toll free, (800) 366-7266. Each investor should carefully read the SA Fund's prospectus and Statement of Additional Information.

ADV Part 2
 
Privacy Policy & Code of Ethics
 
   

Loring Ward Corporate Office
3055 Olin Avenue, Suite 2000
San Jose, CA 95128

Telephone: (408) 260-3100
Toll Free: (800) 366-7266

Public Relations
William Chettle
Managing Director of Marketing & Communications

Telephone: (646) 285-4785
Email: wchettle@loringward.com

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