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Regarding All Season Financial Advisors:
All Season Financial Advisors is an SEC registered investment adviser located in Denver, Colorado. All Season Financial Advisors and its representatives are in compliance with the current filing requirements imposed upon SEC registered investment advisors by those states in which All Season Financial Advisors maintains clients. All Season Financial Advisors may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. All Season Financial Advisors' web site is limited to the dissemination of general information pertaining to its investment advisory services. Accordingly, the publication of the All Season Financial Advisors' web site should not be construed by any consumer and/or prospective client as All Season Financial Advisors' solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the internet. Any subsequent, direct communication by All Season Financial Advisors with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of All Season Financial Advisors, please contact the SEC or the state securities law administrators for those states in which All Season Financial Advisors maintains a notice filing. A copy of All Season Financial Advisors' current written disclosure statement discussing All Season Financial Advisors' business operations, services, and fees is available from All Season Financial Advisors upon request.
Past performance may not be indicative of future results. Therefore, no current or prospective client should assume that future performance of any specific investment, investment strategy (including the investments and/or investment strategies recommended and/or purchased by All Season Financial Advisors) or product made reference to directly or indirectly in this web site, or indirectly via a link to an unaffiliated third party web site, will be profitable or equal the corresponding indicated performance level(s). Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client or prospective client's investment portfolio. Historical performance results for investment indices and/or categories generally do not reflect the deduction of transaction and/or custodial charges, nor the deduction of an investment management fee, the incurrence of which would have the effect of decreasing historical performance results.
Certain portions of this web site (i.e., Updates, newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to other All Season Financial Advisors' (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Moreover, no client or prospective client should assume that any such discussion serves as a substitute for personalized advice from All Season Financial Advisors or from any other investment professional. To the extent that any client or prospective client utilizes any economic calculator or similar device contained within or linked to this web site, the client and/or prospective client is advised that the information resulting from the use of any such calculator/device, is not, and should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from All Season Financial Advisors. Strategic asset allocation strategies may involve an above-average portfolio turnover, which could negatively impact upon an investor's net after-tax investment gain. Information pertaining to All Season Financial Advisors' advisory operations, services, and fees is set forth in the specific advisor's current disclosure statement, as same is on file with the United States Securities and Exchange Commission, a copy of which is available upon request.
COMPOSITE PERFORMANCE DISCLOSURE
Updated December 2018
All Season Financial Advisors, Inc. ("ASFA") composite performance results reflect time-weighted rates of returns of a composite of actual portfolios which have traded equities based upon ASFA's proprietary trading strategies. Whenever possible, we attempt to use accounts with no additions or withdrawals. Accounts are excluded from the composite according to our Account Exclusion Policy below. Results from these excluded accounts may differ substantially from the composite. In some cases, we rely on only 2 or 3 actual accounts for the calculation of the composite return which are accounts we believe to be historically representative of the ASFA portfolio strategy during the corresponding time period. Performance results reflect the deduction of management fees and transaction fees. Prior to 2018, not all accounts had equity dividends and other earnings reinvested. Management fees range between 0.75% and 2.0% of assets depending on the size of the account and are calculated quarterly based on the market value balance at the beginning of the quarter. Historical performance results for investment indices and/or categories generally do not reflect the deduction of transaction and/or custodial charges, nor the deduction of an investment management fee, the incurrence of which would have the effect of decreasing the historical performance results of the index.
Past performance may not be indicative of future results and the performance of a specific individual account may vary substantially from the composite performance. Therefore, no current or prospective client should assume that future performance will be profitable or equal the composite performance results reflected herein. In calculating account performance, ASFA has relied upon information provided by various sources, primarily the account's custodian(s).
Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client or prospective client's investment portfolio. ASFA's investment strategies may involve above-average portfolio turnover, which could negatively impact the net after-tax gain experienced by an individual client. In the event there has been a change in a client's investment objectives or financial situation, he/she/it is encouraged to advise ASFA immediately.
For reasons including variances in portfolio account holdings, variances in the investment management fee incurred, market fluctuation, the date on which a client engaged ASFA's investment management services, and any account contributions or withdrawals, among other variables, the performance of a specific client's account may have varied substantially from the indicated ASFA portfolio performance results. In addition, the underlying individual mutual funds that has comprised, and will continue to comprise, the model programs have changed, and are subject to continued change, at the discretion of ASFA. Historical information pertaining to the underlying mutual funds and changes thereto is available from ASFA upon request.
All composite performance results are currently compiled by Orion Advisory Services, a third-party back office service bureau responsible for client statements, billing and performance reporting. ASFA also maintains all information supporting the performance
results in accordance with regulatory requirements. Information pertaining to ASFA's advisory operations, services, and fees is set forth in ASFA's current disclosure statement, a copy of which is available from ASFA upon request. Information pertaining to any mutual fund that is a current component of an ASFA portfolio is set forth in each respective mutual fund's prospectus, a copy of which is also available from ASFA upon request.
Account Exclusion Policy
An account will be excluded from the composite if it meets any one of the following criteria:
1. The account was not fully invested in the model during the period. Not all securities were held or the cash position was 3% or more out of balance.
2. Dividends are not reinvested.
3. An addition or withdrawal was made during the period.
4. Management fees are not paid from the account.
5. Management fees for more than one account are paid from the account.
6. A non-standard Management fee is charged to the account
Proxy Voting and IPO Policy
All Season Financial Advisors, Inc (ASFA) does not vote client proxies. Therefore, although Advisor may provide investment advisory services relative to client investment assets, Advisor's clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client's investment assets. Advisor and/or the client shall correspondingly instruct each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client's investment assets. Any questions regarding Advisor's proxy voting policy shall be directed to Samuel Jones, President of All Season Financial Advisors, at (303) 837-1187.
On occasion, All Season Financial Advisors, Inc. ("ASFA "), through its clearing/custodial firm relationships, may have limited access to IPO shares. Except with respect to the limited exception noted below, ASFA generally does not purchase and/or recommend for purchase IPOs for its individual client accounts. The limited exception to the above policy is: (1) for initial public offerings of large recognized company securities (i.e. UPS, Google, etc.), and only to the extent that: (a) ASFA first determines such IPO is suitable for its clients; and, (b) the IPO is available through its existing clearing/custodial firm relationships; or (2) for those individual clients of ASFA who, on a completely unsolicited basis, contact ASFA to request that ASFA purchase a specific IPO for his/her/their/its account, to the extent same has been made available to ASFA . In the event of any such unsolicited request(s), ASFA , after first determining that the client is qualified for such specific IPO (i.e., suitable for the client relative to the client's investment objectives, financial situation, and current asset allocation), may (to the extent possible under the circumstances) purchase such IPO on a pro-rata basis with other unsolicited client requests. To the extent applicable under the circumstances, ASFA will use reasonable efforts to allocate available IPO shares on a fair and equitable basis in accordance with the terms and conditions of the aforementioned policy.
All Season Financial Advisors, Inc. (referred to as "All Season") maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients' nonpublic personal information ("information"). Through this policy and its underlying procedures, All Season attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.
It is the policy of All Season to restrict access to all current and former clients' information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/non-affiliated entities who need to know that information in order to provide products or services to the client. All Season may disclose the client's information if All Season is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with All Season, including, but not limited to the client's other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by All Season in order to facilitate the commencement/continuation/termination of a business relationship between the client and a non-affiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian insurance company, etc.), including information contained in any document completed and/or executed by the client for All Season (i.e., advisory agreement, client information form, etc..), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider. If you prefer that we not disclose nonpublic personal information about you to non-affiliated third parties, you may opt out of those disclosures, that is, you may direct us not to make those disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to non-affiliated third parties, you may contact us at (303) 837-1187 to make this request.
Should you have any questions regarding the above, please contact Samuel F Jones, Chief Compliance Officer.