JP Turner's
JPTCM Managed Account
JP Turner & Company Capital Mangement offers direct asset management services to its advisory clients on both a non-discretionary and discretionary basis. JPTCM’s investment advisor representives act as portfolio managers for these accounts. In a non-discretionary account, the IAR will recommend the purchase or sale of securities. Clients must review and approve these recommendations before the IAR makes any purchase or sale. The IARs will only purchase or sell securities when the transaction has been approved by clients in advance. Alternatively, clients may maintain an account on a discretionary basis if (1) the IAR of the account has been authorized by JPTCM to manage accounts on a discretionary basis and (2) the client has granted discretionary authority to the IAR in the client advisory agreement. The purchase and sale of securities in such accounts do not require advance client approval. JPTCM offers both a wrap and an unbundled pricing structure.

JP Turner & Company Capital Management portfolio managers work with their clients to identify their investment goals and objectives, as well as risk tolerance, in order to create an initial portfolio allocation designed to complement the client’s financial situation and personal circumstances. The portfolio may consist of exchange-traded index funds, mutual funds, equities, bonds and other products that are suitable for the individual client.

The investment strategies utilized and portfolios constructed and managed depend on the individual client’s investment objectives and goals, as provided to the IAR, and on the management style of the IAR. The IAR may purchase, sell, and/or exchange securities, including, but not limited to, mutual funds, equities, fixed income instruments, closed-end mutual funds, exchange traded funds, and variable life and annuity subaccounts. Model portfolios may be used as a part of this strategy. However, each client has the opportunity to place reasonable restrictions on the type of investments to be held in the portfolio. The IAR may periodically rebalance the client’s account to maintain the initially agreed upon strategic and tactical asset allocation. However, no changes are made to the agreed-upon asset allocation in nondiscretionary accounts without prior client review and consent.

IARs and thier clients also have the option of utilizing an asset allocation system known as AssetMark Investment Services. AssetMark provides analytical tools to assist IARs in the selection and management of traditional mutual fund, exchange-traded fund, and variable annuity subaccount asset allocation model portfolios.

Clients have ready access to their respective portfolio manager/IAR. Portfolio managers are not required to be available for unscheduled or unannounced visits by clients. However, portfolio managers are expected to periodically meet with clients and should generally be available to take client telephone calls on advisory-related matters.

JP Turner's
MAS Advisory Program Services

One of the services JPTCM provides is the MAS Advisory Program (the program) which consists of:

• MAS Separately Managed Account Program (SMA)
• MAS Multi-Manager Account Program (MMA)
• MAS Strategic Advisors Mutual Fund Portfolio Program (WRAP)
• MAS Model Management (in which the IAR serves as the portfolio manager)

Under the Program, the client and the advisor compile pertinent financial and personal information to develop an investment program designed to help the client meet his or her goals and objectives. Through a third-party vendor, Envestnet (Platform Manager), the IAR employs a software system that assists in analyzing the client information and recommending an appropriate strategy based on the client’s needs and objectives, investment time horizon, risk tolerance and any other pertinent factors.

JP Turner's
MAS Separately Managed Account Program (SMA)
SMA allows the advisor to select and create portfolios of separate account managers. For clients employing the MAS Separately Managed Account Program (SMA), the advisor will recommend individual asset managers from a database provided through a third party vendor – Envestnet, that correspond to the proposed asset classes and styles. Advisor evaluates managers specializing in each of the asset categories listed, including equities (both domestic and foreign); corporate debt; commercial paper; certificates of deposit; municipal securities; mutual funds; real estate investment trusts; government securities; options; and futures. The program includes performance reporting, associated services and support (trading, reconciliation, fee calculation, etc).

JP Turner's
MAS Multi-Manager Account Program (MMA)
MMA provides portfolios based on the client’s risk/needs profile. Separate managers within the portfolio are selected, monitored, and replaced, when deemed necessary by Envestnet. Envestnet has developed and implemented a program to collect, analyze and report data on each manager's investment style and philosophy, past performance, and personnel. All asset allocation and trading are handled by Envestnet. MMA includes performance reporting, associated services and support.

JP Turner's
MAS Strategic Advisers Mutual Fund Portfolio (WRAP)
This is a mutual fund wrap program where, based on the client’s risk/needs profile, the mutual funds are selected, monitored and managed by Strategic Advisers Inc., a wholly owned subsidiary of Fidelity Investments. This program includes quarterly performance reporting, associated services and support. (Mutual funds invove market risk, including fluctuating returns and possible loss of principal.)

JP Turner's
MAS Model Management Rep as Portfolio Manager (in which the IAR serves as portfolio manager)
Rep as Portfolio Manager is a wrap account where the IAR manages the client’s account and creates, monitors, and adjusts model portfolios. For clients employing the MAS Model Management (Rep as Portfolio Manager Program), the IAR will recommend investment vehicles that correspond to the proposed asset classes and styles. The client is provided with an initial allocation that corresponds to the individual client’s goals and objectives. Once the client’s assets are invested, the IAR may add, remove or replace investments at his or her discretion. The program includes a risk questionnaire, rebalancing, drift controls, system alerts and a multiple report capability. Under this program, Sponsor does not review the portfolio manager’s performance information. Clients that participate in the Program are required to grant full discretionary investment authority to the IAR. The IAR will use his or her discretion to replace investment vehicles, including sub-managers, when it deems such a change is necessary; to rebalance a client’s account as agreed between the client and the IAR, and to liquidate sufficient assets to pay the Program fee when necessary and any other actions that the IAR deems appropriate.

The IAThe IAR will recommend an asset allocation and construct a portfolio based upon the client’s needs and objectives. In some cases, third-party managers will supply the IAR with a model portfolio, and the IAR will invest client assets accordingly.

JP Turner & Company Capital Management's IAR will review the investment strategies and performance of a wide range of managers. From time to time, managers of non-traditional or alternative investment strategies will be recommended to clients if these manager's products meet the client's suitability criteria.