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Home My WebLink About20222954.tiffC&1-h7�* ttfr0/ PROFESSIONAL SERVICE AGREEMENT BETWEEN WELD COUNTY AND CHANDLER ASSET MANAGEMENT, INC. THIS AGREEMENT is made and entered into this 28th day of November, 2022, by and between the Board of Weld County Commissioners, on behalf of the Finance Department, hereinafter referred to as "County," and Chandler Asset Management, Inc., hereinafter referred to as "Contractor". WHEREAS, County desires to retain Contractor to perform services as required by County and set forth in the attached Exhibits; and WHEREAS, Contractor is willing and has the specific ability, qualifications, and time to perform the required services according to the terms of this Agreement; and WHEREAS, Contractor is authorized to do business in the State of Colorado and has the time, skill, expertise, and experience necessary to provide the services as set forth below. NOW, THEREFORE, in consideration of the mutual promises and covenants contained herein, the parties hereto agree as follows: 1. Introduction. The terms of this Agreement are contained in the terms recited in this document and in the attached Exhibits, each of which forms an integral part of this Agreement and are incorporated herein. The parties each acknowledge and agree that this Agreement, including the attached Exhibits, define the performance obligations of Contractor and Contractor's willingness and ability to meet those requirements (the "Work"). If a conflict occurs between this Agreement and any Exhibit or other attached document, the terms of this Agreement shall control, and the remaining order of precedence shall based upon order of attachment. Exhibit A consists of County's Request for Bid (RFB) or Request for Proposal (RFP) as set forth in Bid Package No. B2200146. Exhibit B consists of Contractor's Response to County's Request (redacted EIN on W-9 Form and Section I Financial Statements). Exhibit C consists of Contractor's Best and Final Fee Offer. Exhibit D consist of Contractor's Additional Terms Specific to Investment Management Relationship. 2. Service or Work. Contractor agrees to procure the materials, equipment and/or products necessary for the Work and agrees to diligently provide all services, labor, personnel and materials necessary to perform and complete the Work described in the attached Exhibits. Contractor shall further be responsible for the timely completion and acknowledges that a failure to comply with the standards and requirements of Work within the time limits prescribed by County may result in County's decision to withhold payment or to terminate this Agreement. Consent k3exicia-- t Mr22 ii/a8/ate 2022- 29 5,4 3. Term. The term of this Agreement begins upon the date of the mutual execution of this Agreement and shall continue through and until Contractor's completion of the responsibilities described in the attached Exhibits. Both of the parties to this Agreement understand and agree that the laws of the State of Colorado prohibit County from entering into Agreements which bind County for periods longer than one year. This Agreement may be extended upon mutual written agreement of the Parties. 4. Termination; Breach; Cure. County may terminate this Agreement for its own convenience upon thirty (30) days written notice to Contractor. Either Party may immediately terminate this Agreement upon material breach of the other party, however the breaching party shall have fifteen (15) days after receiving such notice to cure such breach. Upon termination, County shall take possession of all materials, equipment, tools and facilities owned by County which Contractor is using, by whatever method it deems expedient; and, Contractor shall deliver to County all drawings, drafts, or other documents it has completed or partially completed under this Agreement, together with all other items, materials and documents which have been paid for by County, and these items, materials and documents shall be the property of County. Copies of work product that is incomplete at the time of termination shall be marked "DRAFT - INCOMPLETE." If this Agreement is terminated by County, Contractor shall be compensated for, and such compensation shall be limited to, (1) the sum of the amounts contained in invoices which it has submitted and which have been approved by the County; (2) the reasonable value to County of the services which Contractor provided prior to the date of the termination notice, but which had not yet been approved for payment; and (3) the cost of any work which the County approves in writing which it determines is needed to accomplish an orderly termination of the work. County shall be entitled to the use of all material generated pursuant to this Agreement upon termination. Upon termination of this Agreement by County, Contractor shall have no claim of any kind whatsoever against the County by reason of such termination or by reason of any act incidental thereto, except for compensation for work satisfactorily performed and/or materials described herein properly delivered. 5. Extension or Amendment. Any amendments or modifications to this agreement shall be in writing signed by both parties. No additional services or work performed by Contractor shall be the basis for additional compensation unless and until Contractor has obtained written authorization and acknowledgement by County for such additional services. Accordingly, no claim that the County has been unjustly enriched by any additional services, whether or not there is in fact any such unjust enrichment, shall be the basis of any increase in the compensation payable hereunder. In the event that written authorization and acknowledgment by the County for such additional services is not timely executed and issued in strict accordance with this Agreement, Contractor's rights with respect to such additional services shall be deemed waived and such failure shall result in non-payment for such additional services or work performed. In the event the County shall require changes in the scope, character, or complexity of the work to be performed, and said changes cause an increase or decrease in the time required or the costs to the Contractor for performance, an equitable adjustment in fees and completion time shall be negotiated between the parties and this Agreement shall be modified accordingly by Change Order. Any claims by the Contractor for adjustment hereunder must be made in writing prior to performance of any work covered in the anticipated Change Order, unless approved and documented otherwise by the County Representative. Any change in work made without such 2 prior Change Order shall be deemed covered in the compensation and time provisions of this Agreement, unless approved and documented otherwise by the County Representative. 6. Compensation. Upon Contractor's successful completion of the Work, and County's acceptance of the same, County agrees to pay Contractor an amount of 0.06 of 1% (6 basis points) for the first $150 million of assets under the Contractor's management and 0.03 of 1% (3 basis points) for assets over $150 million under the Contractor's management as set for the in the Exhibits. The fee will be calculated and billed monthly in arrears, on the average market value of County's portfolio, including accrued interest. No payment in excess of that set forth in the Exhibits will be made by County unless a Change Order authorizing such additional payment has been specifically approved by Weld County as required pursuant to the Weld County Code. If, at any time during the term or after termination or expiration of this Agreement, County reasonably determines that any payment made by County to Contractor was improper because the service for which payment was made did not perform as set forth in this Agreement, then upon written notice of such determination and request for reimbursement from County, Contractor shall forthwith return such payment(s) to County. Upon termination or expiration of this Agreement, unexpended funds advanced by County, if any, shall forthwith be returned to County. County will not withhold any taxes from monies paid to the Contractor hereunder and Contractor agrees to be solely responsible for the accurate reporting and payment of any taxes related to payments made pursuant to the terms of this Agreement. Unless expressly enumerated in the attached Exhibits, Contractor shall not be entitled to be paid for any other expenses (e.g. mileage). Notwithstanding anything to the contrary contained in this Agreement, County shall have no obligations under this Agreement after, nor shall any payments be made to Contractor in respect of any period after December 31 of any year, without an appropriation therefore by County in accordance with a budget adopted by the Board of County Commissioners in compliance with Article 25, Title 30 of the Colorado Revised Statutes, the Local Government Budget Law (C.R.S. 29-1-101 et. seq.) and the TABOR Amendment (Colorado Constitution, Article X, Sec. 20). 7. Independent Contractor. Contractor agrees that it is an independent contractor and that Contractor's officers, agents or employees will not become employees of County, nor entitled to any employee benefits (including unemployment insurance or workers' compensation benefits) from County as a result of the execution of this Agreement. Contractor shall be solely responsible for its acts and those of its agents and employees for all acts performed pursuant to this Agreement. 8. Subcontractors. Contractor acknowledges that County has entered into this Agreement in reliance upon the particular reputation and expertise of Contractor. Contractor shall not enter into any subcontractor agreements for the completion of the Work without County's prior written consent, which may be withheld in County's sole discretion. County shall have the right in its reasonable discretion to approve all personnel assigned to the Work during the performance of this Agreement and no personnel to whom County has an objection, in its reasonable discretion, shall be assigned to the Work. Contractor shall require each subcontractor, as approved by County and to the extent of the Work to be performed by the subcontractor, to be bound to Contractor by the terms of this Agreement, and to assume toward Contractor all the obligations and responsibilities which Contractor, by this Agreement, assumes toward County. County shall have the right (but not the obligation) to enforce the provisions of this Agreement against any 3 subcontractor hired by Contractor and Contractor shall cooperate in such process. The Contractor shall be responsible for the acts and omissions of its agents, employees and subcontractors. 9. Ownership. All work and information obtained by Contractor under this Agreement or individual work order shall become or remain (as applicable), the property of County. In addition, all reports, documents, data, plans, drawings, records and computer files generated by Contractor in relation to this Agreement and all reports, test results and all other tangible materials obtained and/or produced in connection with the performance of this Agreement, whether or not such materials are in completed form, shall at all times be considered the property of the County. Contractor shall not make use of such material for purposes other than in connection with this Agreement without prior written approval of County. 10. Confidentiality. Confidential information of the Contractor should be transmitted separately from non -confidential information, clearly denoting in red on the relevant document at the top the word, "CONFIDENTIAL." However, Contractor is advised that as a public entity, Weld County must comply with the provisions of the Colorado Open Records Act (CORA), C.R.S. 24-72-201, et seq., with regard to public records, and cannot guarantee the confidentiality of all documents. Contractor agrees to keep confidential all of County's confidential information. Contractor agrees not to sell, assign, distribute, or disclose any such confidential information to any other person or entity without seeking written permission from the County. Contractor agrees to advise its employees, agents, and consultants, of the confidential and proprietary nature of this confidential information and of the restrictions imposed by this Agreement. 11. Warranty. Contractor warrants that the Work performed under this Agreement will be performed in a manner consistent with the standards governing such services and the provisions of this Agreement. Contractor further represents and warrants that all Work shall be performed by qualified personnel in a professional manner, consistent with industry standards, and that all services will conform to applicable specifications. For work in which Contractor produces a design to be used for construction purposes, Contractor shall carefully check all unit quantities and quantity calculations and shall submit them for County review. If the County experiences additional costs during project construction which are directly associated with errors and omissions (professional negligence) which require change orders to the construction contract resulting in costs greater than the construction contract bid unit costs, Contractor shall be financially liable for such increased costs. 12. Acceptance of Services Not a Waiver. Upon completion of the Work, Contractor shall submit to County originals of all test results, reports, etc., generated during completion of this work. Acceptance by County of reports and incidental material(s) furnished under this Agreement shall not in any way relieve Contractor of responsibility for the quality and accuracy of the project. In no event shall any action by County hereunder constitute or be construed to be a waiver by County of any breach of this Agreement or default which may then exist on the part of Contractor, and County's action or inaction when any such breach or default exists shall not impair or prejudice any right or remedy available to County with respect to such breach or default. No assent, expressed or implied, to any breach of any one or more covenants, provisions or conditions of the Agreement shall be deemed or taken to be a waiver of any other breach. Acceptance by the County of, or payment for, the Work completed under this Agreement shall not 4 be construed as a waiver of any of the County's rights under this Agreement or under the law generally. 13. Insurance. Contractor must secure, before the commencement of the Work, the following insurance covering all operations, goods, and services provided pursuant to this Agreement, and shall keep the required insurance coverage in force at all times during the term of the Agreement, or any extension thereof, and during any warranty period. For all coverages, Contractor's insurer shall waive subrogation rights against County. a. Types of Insurance. Workers' Compensation / Employer's Liability Insurance as required by state statute, covering all of the Contractor's employees acting within the course and scope of their employment. The policy shall contain a waiver of subrogation against the County. This requirement shall not apply when a Contractor or subcontractor is exempt under Colorado Workers' Compensation Act., AND when such Contractor or subcontractor executes the appropriate sole proprietor waiver form. Commercial General Liability Insurance including public liability and property damage, covering all operations required by the Work. Such policy shall include minimum limits as follows: $1,000,000 each occurrence; $1,000,000 general aggregate; $1,000,000 Personal injury $5,000; Medical payment per person. Automobile Liability Insurance: Contractor shall maintain limits of $1,000,000 for bodily injury per person, $1,000,000 for bodily injury for each accident, and $1,000,000 for property damage applicable to all vehicles operating both on County property and elsewhere, for vehicles owned, hired, and non -owned vehicles used in the performance of this Contract. Professional Liability (Errors and Omissions Liability). The policy shall cover professional misconduct or lack of ordinary skill for those positions defined in the Scope of Services of this contract. Contractor shall maintain limits for all claims covering wrongful acts, errors and/or omissions, including design errors, if applicable, for damage sustained by reason of or in the course of operations under this Contract resulting from professional services. In the event that the professional liability insurance required by this Contract is written on a claims -made basis, Contractor warrants that any retroactive date under the policy shall precede the effective date of this Contract; and that either continuous coverage will be maintained or an extended discovery period will be exercised for a period of two (2) years beginning at the time work under this Contract is completed. Minimum Limits: $1,000,000 Per Loss; $2,000,000 Aggregate. b. Proof of Insurance. Upon County's request, Contractor shall provide to County a certificate of insurance, a policy, or other proof of insurance as determined in County's sole discretion. County may require Contractor to provide a certificate of insurance naming Weld County, Colorado, its elected officials, and its employees as an additional named insured. 5 c. Subcontractor Insurance. Contractor hereby warrants that all subcontractors providing services under this Agreement have or will have the above described insurance prior to their commencement of the Work, or otherwise that they are covered by the Contractor's policies to the minimum limits as required herein. Contractor agrees to provide proof of insurance for all such subcontractors upon request by the County. d. No limitation of Liability. The insurance coverages specified in this Agreement are the minimum requirements, and these requirements do not decrease or limit the liability of Contractor. The County in no way warrants that the minimum limits contained herein are sufficient to protect the Contractor from liabilities that might arise out of the performance of the Work under by the Contractor, its agents, representatives, employees, or subcontractors. The Contractor shall assess its own risks and if it deems appropriate and/or prudent, maintain higher limits and/or broader coverages. The Contractor is not relieved of any liability or other obligations assumed or pursuant to the Contract by reason of its failure to obtain or maintain insurance in sufficient amounts, duration, or types. The Contractor shall maintain, at its own expense, any additional kinds or amounts of insurance that it may deem necessary to cover its obligations and liabilities under this Agreement. e. Certification of Compliance with Insurance Requirements. The Contractor stipulates that it has met the insurance requirements identified herein. The Contractor shall be responsible for the professional quality, technical accuracy, and quantity of all services provided, the timely delivery of said services, and the coordination of all services rendered by the Contractor and shall, without additional compensation, promptly remedy and correct any errors, omissions, or other deficiencies. 14. Indemnity. The Contractor shall defend, indemnify and hold harmless County, its officers, agents, and employees, from and against any and all injury, loss, damage, liability, suits, actions, claims, or willful acts or omissions of any type or character arising out of the Work done in fulfillment of the terms of this Agreement or on account of any act, claim or amount arising or recovered under workers' compensation law or arising out of the failure of the Contractor to conform to any statutes, ordinances, regulation, judicial decision, or other law or court decree. The Contractor shall be fully responsible and liable for any and all injuries or damage received or sustained by any person, persons, or property on account of its performance under this Agreement or its failure to comply with the provisions of the Agreement. It is agreed that the Contractor will be responsible for primary loss investigation, defense and judgment costs where this contract of indemnity applies. In consideration of the award of this contract, the Contractor agrees to waive all rights of subrogation against the County its associated and/or affiliated entities, successors, or assigns, its elected officials, trustees, employees, agents, and volunteers for losses arising from the work performed by the Contractor for the County. A failure to comply with this provision shall result in County's right to immediately terminate this Agreement. 15. Non -Assignment. Contractor may not assign or transfer this Agreement or any interest therein or claim thereunder, without the prior written approval of County. Any attempts by Contractor to assign or transfer its rights hereunder without such prior approval by County shall, at the option of County, automatically terminate this Agreement and all rights of Contractor hereunder. Such consent may be granted or denied at the sole and absolute discretion of County. 6 16. Examination of Records. To the extent required by law, the Contractor agrees that an duly authorized representative of County, including the County Auditor, shall have access to and the right to examine and audit any books, documents, papers and records of Contractor, involving all matters and/or transactions related to this Agreement. Contractor agrees to maintain these documents for three years from the date of the last payment received. 17. Interruptions. Neither party to this Agreement shall be liable to the other for delays in delivery or failure to deliver or otherwise to perform any obligation under this Agreement, where such failure is due to any cause beyond its reasonable control, including but not limited to Acts of God, fires, strikes, war, flood, earthquakes or Governmental actions. 18. Notices. County may designate, prior to commencement of Work, its project representative ("County Representative") who shall make, within the scope of his or her authority, all necessary and proper decisions with reference to the project. All requests for contract interpretations, change orders, and other clarification or instruction shall be directed to County Representative. All notices or other communications made by one party to the other concerning the terms and conditions of this contract shall be deemed delivered under the following circumstances: (a) personal service by a reputable courier service requiring signature for receipt; or (b) five (5) days following delivery to the United States Postal Service, postage prepaid addressed to a party at the address set forth in this contract; or (c) electronic transmission via email at the address set forth below, where a receipt or acknowledgment is required and received by the sending party; or Either party may change its notice address(es) by written notice to the other. Notice may be sent to: TO CONTRACTOR: Name: Nicole Dragoo Position: President Address: 6225 Lusk Boulevard Address: San Diego, CA 92121 E-mail: ndragoo@chandlerasset.com Phone: 800-317-4747 TO COUNTY: Name: Cheryl Pattelli Position: CFO Address: 1150 O Street Address: Greeley, CO 80632 E-mail: cpattelli@weldgov.com Phone: 970-400-4451 7 19. Compliance with Law. Contractor shall strictly comply with all applicable federal and State laws, rules and regulations in effect or hereafter established, including without limitation, laws applicable to discrimination and unfair employment practices. 20. Non -Exclusive Agreement. This Agreement is nonexclusive and County may engage or use other Contractors or persons to perform services of the same or similar nature. 21. Entire Agreement/Modifications. This Agreement including the Exhibits attached hereto and incorporated herein, contains the entire agreement between the parties with respect to the subject matter contained in this Agreement. This instrument supersedes all prior negotiations, representations, and understandings or agreements with respect to the subject matter contained in this Agreement. This Agreement may be changed or supplemented only by a written instrument signed by both parties. 22. Fund Availability. Financial obligations of the County payable after the current fiscal year are contingent upon funds for that purpose being appropriated, budgeted and otherwise made available. Execution of this Agreement by County does not create an obligation on the part of County to expend funds not otherwise appropriated in each succeeding year. 23. Employee Financial Interest/Conflict of Interest — C.R.S. §§24-18-201 et seq. and §24- 50-507. The signatories to this Agreement state that to their knowledge, no employee of Weld County has any personal or beneficial interest whatsoever in the service or property which is the subject matter of this Agreement. 24. Survival of Termination. The obligations of the parties under this Agreement that by their nature would continue beyond expiration or termination of this Agreement (including, without limitation, the warranties, indemnification obligations, confidentiality and record keeping requirements) shall survive any such expiration or termination. 25. Severability. If any term or condition of this Agreement shall be held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, this Agreement shall be construed and enforced without such provision, to the extent that this Agreement is then capable of execution within the original intent of the parties. 26. Governmental Immunity. No term or condition of this Agreement shall be construed or interpreted as a waiver, express or implied, of any of the immunities, rights, benefits, protections or other provisions, of the Colorado Governmental Immunity Act §§24-10-101 et seq., as applicable now or hereafter amended. 27. No Third Party Beneficiary. It is expressly understood and agreed that the enforcement of the terms and conditions of this Agreement, and all rights of action relating to such enforcement, shall be strictly reserved to the undersigned parties and nothing in this Agreement shall give or allow any claim or right of action whatsoever by any other person not included in this Agreement. It is the express intention of the undersigned parties that any entity other than the undersigned parties receiving services or benefits under this Agreement shall be an incidental beneficiary only. 8 28. Board of County Commissioners of Weld County Approval. This Agreement shall not be valid until it has been approved by the Board of County Commissioners of Weld County, Colorado or its designee. 29. Choice of Law/Jurisdiction. Colorado law, and rules and regulations established pursuant thereto, shall be applied in the interpretation, execution, and enforcement of this Agreement. Any provision included or incorporated herein by reference which conflicts with said laws, rules and/or regulations shall be null and void. In the event of a legal dispute between the parties, Contractor agrees that the Weld County District Court shall have exclusive jurisdiction to resolve said dispute. 30. Public Contracts for Services C.R.S. §8-17.5-101. Contractor certifies, warrants, and agrees that it does not knowingly employ or contract with an illegal alien who will perform work under this Agreement. Contractor will confirm the employment eligibility of all employees who are newly hired for employment in the United States to perform work under this Agreement, through participation in the E -Verify program or the State of Colorado program established pursuant to C.R.S. §8-17.5-102(5)(c). Contractor shall not enter into a contract with a subcontractor that fails to certify with Contractor that the subcontractor shall not knowingly employ or contract with an illegal alien to perform work under this Agreement. Contractor shall not use E -Verify Program or State of Colorado program procedures to undertake pre -employment screening or job applicants while this Agreement is being performed. If Contractor obtains actual knowledge that a subcontractor performing work under this Agreement knowingly employs or contracts with an illegal alien Contractor shall notify the subcontractor and County within three (3) days that Contractor has actual knowledge that a subcontractor is employing or contracting with an illegal alien and shall terminate the subcontract if a subcontractor does not stop employing or contracting with the illegal alien within three (3) days of receiving notice. Contractor shall not terminate the subcontract if within three days the subcontractor provides information to establish that the subcontractor has not knowingly employed or contracted with an illegal alien. Contractor shall comply with reasonable requests made in the course of an investigation, undertaken pursuant to C.R.S. §8-17.5-102(5), by the Colorado Department of Labor and Employment. If Contractor participates in the State of Colorado program, Contractor shall, within twenty days after hiring an new employee to perform work under the contract, affirm that Contractor has examined the legal work status of such employee, retained file copies of the documents, and not altered or falsified the identification documents for such employees. Contractor shall deliver to County, a written notarized affirmation that it has examined the legal work status of such employee and shall comply with all of the other requirements of the State of Colorado program. If Contractor fails to comply with any requirement of this provision or of C.R.S. §8-17.5-101 et seq., County, may terminate this Agreement for breach, and if so terminated, Contractor shall be liable for actual and consequential damages. Except where exempted by federal law and except as provided in C.R.S. § 24-76.5-103(3), if Contractor receives federal or state funds under the contract, Contractor must confirm that any individual natural person eighteen (18) years of age or older is lawfully present in the United States pursuant to C.R.S. § 24-76.5-103(4), if such individual applies for public benefits provided under the contract. If Contractor operates as a sole proprietor, it hereby swears or affirms under penalty of perjury that it: (a) is a citizen of the United States or is otherwise lawfully present in the United 9 States pursuant to federal law, (b) shall produce one of the forms of identification required by C.R.S. § 24-76.5-101, et seq., and (c) shall produce one of the forms of identification required by C.R.S. § 24-76.5-103 prior to the effective date of the contract. 31. Attorney's Fees/Legal Costs. In the event of a dispute between County and Contractor concerning this Agreement, the parties agree that each party shall be responsible for the payment of attorney fees aid/or legal costs incurred by or on its own behalf. 32. Binding Arbitration Prohibited. Weld County does not agree to binding arbitration by any extra judicial body or person. Any provision to the contrary in this Agreement or incorporated herein by reference shall be null and void. Acknowledgment. County and Contractor acknowledge that each has read this Agreement, understands it and agrees to be bound by its terms. Both parties further agree that this Agreement, with the attached Exhibits, is the complete and exclusive statement of agreement between the parties and supersedes all proposals or prior agreements, oral or written, and any other communications between the parties relating to the subject matter of this Agreement. CONTRACTOR: Chandler Asset Management, Inc. By: Name: Nicole Dr o Title: President 11/15/2022 Date of Signature WELD TOL-- - `, .� ATTEST ,/ �o� Weld o t Clerk to th; Board BY Deputy Clerk the :oar," 10 BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ott K. James, Chair NOV 2 8 2022 o&oZo2 - 029 Exhibit A REQUEST FOR PROPOSALS WELD COUNTY, COLORADO 1150 O STREET GREELEY, CO 80631 DATE: September 21, 2022 PROPOSAL NUMBER: B2200146 DESCRIPTION: Investment Advisor Services DEPARTMENT: Finance BID OPENING DATE: October 19, 2022 1. NOTICE TO VENDORS: The Board of County Commissioners of Weld County, Colorado, by and through its Controller (collectively referred to herein as, "Weld County"), wishes to purchase the following: INVESTMENT ADVISOR SERVICES Question submission deadline: October 5, 2022, by 5:00 PM. Email questions to: Cheryl Pattelli, CFO, cpattellitweldgov.com. Questions and Answers will be posted on https://www.bidnetdirect.com/ on or before October 10, 2022, by 5:00 PM. Proposals will be received until: October 19, 2022, at 10:00 AM (Weld County Purchasing Time Clock). The submitted proposals will be read over a Microsoft Teams Conference Call on October 19 at 10:30 AM. To join, call the phone number and enter the Conference ID provided below or you are invited to attend the bid opening in person at the Weld County Administration Building, Fort St. Vrain Meeting Room, 1150 O Street, Greeley, CO 80631. Phone number: 720-439-5261 Phone Conference ID: 342 509 119# PAGES 1 - 8 OF THIS REQUEST FOR PROPOSALS CONTAINS GENERAL INFORMATION FOR THE REQUEST NUMBER REFERRED TO ABOVE. NOT ALL OF THE INFORMATION CONTAINED IN PAGES 1 - 8 MAY BE APPLICABLE FOR EVERY PURCHASE. PROPOSAL SPECIFICS FOLLOW PAGE 8. 2. INVITATION TO PROPOSE: Weld County requests proposals for the above -listed merchandise, equipment, and/or services. Said merchandise and/or equipment shall be delivered to the location(s) specified herein. Proposals shall include any and all charges for freight, delivery, containers, packaging, less all taxes and discounts, and shall, in every way, be the total net price which the Vendor will expect Weld County to pay if awarded the proposal. You can find information concerning this request on the BidNet Direct website at https://www.bidnetdirect.com/. Weld County Government is a member of BidNet Direct which is an online notification system being utilized by multiple non-profit and governmental entities. Participating entities post their bids, quotes, proposals, addendums, and awards on this one centralized system. Proposal Delivery to Weld County: 1. Emailed proposals are required. Email proposals to bids@weldgov.com; however, if your proposal exceeds 25MB please upload it to https://www.bidnetdirect.com. The maximum file size to upload to BidNet Direct is 500 MB. PDF format is required. Emailed proposals must include the following statement on the email: "I hereby waive my right to a sealed proposal". An email confirmation will be sent when your proposal is received. Please call Purchasing at 970-400-4222 or 4223 with any questions. 3. INSTRUCTIONS TO VENDORS: INTRODUCTORY INFORMATION: Proposals shall be typewritten or written in ink on forms prepared by the Weld County Purchasing Department. Each proposal must give the full business address of vendor and be signed by him with his usual signature. Proposals by partnerships must furnish the full names of all partners and must be signed with the partnership name by one of the members of the partnership or by an authorized representative, followed by the signature and title of the person signing. Proposals by corporations must be signed with the legal name of the corporation, followed by the name of the state of the incorporation and by the signature and title of the president, secretary, or other person authorized to bind it in the matter. The name of each person signing shall also be typed or printed below the signature. A proposal by a person who affixes to his signature the word "president," "secretary," "agent," or other title without disclosing his principal, may be held to be the proposal of the individual signing. When requested by the Weld County Controller, satisfactory evidence of the authority of the officer signing on behalf of a corporation shall be furnished. A power of attorney must accompany the signature of anyone not otherwise authorized to bind the Vendor. All corrections or erasures shall be initialed by the person signing the proposal. All vendors shall agree to comply with all of the conditions, requirements, specifications, and/or instructions of this proposal as stated or implied herein. All designations and prices shall be fully and clearly set forth. All blank spaces in the proposal forms shall be suitably filled in. Vendors are required to use the Proposal Forms which are included in this package and on the basis indicated in the Proposal Forms. The Proposal must be filled out completely, in detail, and signed by the Vendor. Late or unsigned proposals shall not be accepted or considered. It is the responsibility of the Vendor to ensure that the proposal arrives in the Weld County Purchasing Department on or prior to the time indicated in Section 1, entitled, "Notice to Vendors." Proposals received prior to the time of opening will be kept u nopened in a secure place. No responsibility will attach to the Weld County Controller for the premature o pening of a proposal not properly addressed and identified. Proposals may be withdrawn upon written request to and approval of the Weld County Controller; said request being received from the withdrawing Vendor prior to the time fixed for award. Negligence on the part of a Vendor in preparing the proposal confers n o right for the withdrawal of the proposal after it has been awarded. Vendors are expected to examine the conditions, specifications, and all instructions contained herein, failure to do so will be at the Vendors' risk. In accordance with Section 14-9(3) of the Weld County Home Rule Charter, Weld County will give preference to resident Weld County Vendors in all cases where said proposals are competitive in price and quality. It is also understood that Weld County will give preference to suppliers from the State of Colorado, in accordance with C.R.S. § 30-11-110 (when it is accepting proposals for the purchase of any books, stationery, records, printing, lithographing or other supplies for any officer of Weld County). Weld County reserves the right to reject any and all proposals, to waive any informality in the proposals, to award the proposal to multiple vendors, and to accept the proposal that, in the opinion of the Board of County Commissioners, is to the best interests of Weld County. The proposal(s) may be awarded to more than one vendor. In submitting the proposal, the Vendor agrees that the signed proposal submitted, all of the documents of the Request for Proposal contained herein (including, but not limited to, product specifications and scope of services), the successful Vendor's response, and the formal acceptance of the proposal by Weld County, together constitutes a contract, with the contract date being the date of formal acceptance of the proposal by Weld County. The County may require a separate contract, which if required, has been made a part of this RFP. 4. GENERAL PROVISIONS: A. Fund Availability: Financial obligations of Weld County payable after the current fiscal year are contingent upon funds for that purpose being appropriated, budgeted and otherwise made available. By PROPOSAL REQUEST #B2200146 Page 2 acceptance of the proposal, Weld County does not warrant that funds will be available to fund the contract beyond the current fiscal year. B. Trade Secrets and other Confidential Information: Weld County discourages Vendors from submitting confidential information, including trade secrets, that cannot be disclosed to the public. If necessary, confidential information of the Vendor shall be transmitted separately from the main proposal submittal, clearly denoting in red on the information at the top the word, "CONFIDENTIAL." However, the successful Vendor is advised that as a public entity, Weld County must comply with the provisions of C.R.S. 24-72-201, et seq., the Colorado Open Records Act (CORA), with regard to public records, and cannot guarantee the confidentiality of all documents. The Vendor is responsible for ensuring that all information contained within the confidential portion of the submittal is exempt from disclosure pursuant to C.R.S. 24-72- 204(3)(a)(IV) (Trade secrets, privileged information, and confidential commercial, financial, geological, or geophysical data). If Weld County receives a CORA request for proposal information marked "CONFIDENTIAL", staff will review the confidential materials to determine whether any of them may be withheld from disclosure pursuant to CORA, and disclose those portions staff determines are not protected from disclosure. Weld County staff will not be responsible for redacting or identifying Confidential information which is included within the body of the proposal and not separately identified. Any document which is incorporated as an exhibit into any contract executed by the County shall be a public document regardless of whether it is marked as confidential. C. Governmental Immunity: No term or condition of the contract shall be construed or interpreted as a waiver, express or implied, of any of the immunities, rights, benefits, protections or other provisions, of the Colorado Governmental Immunity Act §§24-10-101 et seq., as applicable now or hereafter amended. D. Independent Contractor: The successful Vendor shall perform its duties hereunder as an independent contractor and not as an employee. He or she shall be solely responsible for its acts and those of its agents and emp oyees for all acts performed pursuant to the contract. Neither the successful Vendor nor any agent or employee thereof shall be deemed to be an agent or employee of Weld County. The successful Vendor and its employees and agents are not entitled to unemployment insurance or workers' compensation benefits through Weld County and Weld County shall not pay for or otherwise provide such coverage for the successful Vendor or any of its agents or employees. Unemployment insurance benefits will be available to the successful Vendor and its employees and agents only if such coverage is made available by the successful Vendor or a third party. The successful Vendor shall pay when due all applicable employment taxes and income taxes and local head taxes (if applicable) incurred pursuant to the contract. The successful Vendor shall not have authorization, express or implied, to bind Weld County to any agreement, liability or understanding, except as expressly set forth in the contract. The successful Vendor shall have the following responsibilities with regard to workers' compensation and unemployment compensation insurance matters: (a) provide and keep in force workers' compensation and unemployment compensation insurance in the amounts required by law, and (b) provide proof thereof when requested to do so by Weld County. E. Compliance with Law: The successful Vendor shall strictly comply with all applicable federal and state laws, rules and regulations in effect or hereafter established, including without limitation, laws applicable to discrimination and unfair employment practices. F. Choice of Law: Colorado law, and rules and regulations established pursuant thereto, shall be applied in the interpretation, execution, and enforcement of the contract. Any provision included or incorporated herein by reference which conflicts with said laws, rules and/or regulations shall be null and void. G. No Third -Party Beneficiary Enforcement: It is expressly understood and agreed that the enforcement of the terms and conditions of the contract, and all rights of action relating to such enforcement, shall be strictly reserved to the undersigned parties and nothing in the contract shall give or allow any claim or right of action whatsoever by any other person not included in the contract. It is the express intention of PROPOSAL REQUEST #B2200146 Page 3 the undersigned parties that any entity other than the undersigned parties receiving services or benefits under the contract shall be an incidental beneficiary only. H. Attorney's Fees/Legal Costs: In the event of a dispute between Weld County and the successful Vendor, concerning the contract, the parties agree that Weld County shall not be liable to or responsible for the payment of attorney fees and/or legal costs incurred by or on behalf of the successful Vendor. I. Disadvantaged Business Enterprises: Weld County assures that disadvantaged business enterprises will be afforded full opportunity to submit proposals in response to all invitations and will not be discriminated against on the grounds of race, color, national origin, sex, age, or disability in consideration for an award. J. Procurement and Performance: The successful Vendor agrees to procure the materials, equipment and/or products necessary for the project and agrees to diligently provide all services, labor, personnel and materials necessary to perform and complete the project. The successful Vendor shall further be responsible for the timely completion, and acknowledges that a failure to comply with the standards and requirements outlined in the Proposal within the time limits prescribed by County may result in County's decision to withhold payment or to terminate this Agreement. K. Term: The term of this Agreement begins upon the date of the execution of this Agreement by County, and shall continue through and until successful Vendor's completion of the responsibilities described in the Proposal. L. Termination: County has the right to terminate this Agreement, with or without cause on thirty (30) days written notice. Furthermore, this Agreement may be terminated at any time without notice upon a material breach of the terms of the Agreement. M. Extension or Modification: Any amendments or modifications to this agreement shall be in writing signed by both parties. No additional services or work performed by the successful Vendor shall be the basis for additional compensation unless and until the successful Vendor has obtained written authorization and acknowledgement by County for such additional services. Accordingly, no claim that the County has been unjustly enriched by any additional services, whether or not there is in fact any such unjust enrichment, shall be the basis of any increase in the compensation payable hereunder. N. Subcontractors: The successful Vendor acknowledges that County has entered into this Agreement in reliance upon the particular reputation and expertise of the successful Vendor. The successful Vendor shall not enter into any subcontractor agreements for the completion of this Project without County's prior written consent, which may be withheld in County's sole discretion. County shall have the right in its reasonable discretion to approve all personnel assigned to the subject Project during the performance of this Agreement and no personnel to whom County has an objection, in its reasonable discretion, shall be assigned to the Project. The successful Vendor shall require each subcontractor, as approved by County and to the extent of the Services to be performed by the subcontractor, to be bound to the successful Vendor by the terms of this Agreement, and to assume toward the successful Vendor all the obligations and responsibilities which the successful Vendor, by this Agreement, assumes toward County. County shall have the right (but not the obligation) to enforce the provisions of this Agreement against any subcontractor hired by the successful Vendor and the successful Vendor shall cooperate in such process. The successful Vendor shall be responsible for the acts and omissions of its agents, employees and subcontractors. 0. Warranty: The successful Vendor warrants that services performed under this Agreement will be performed in a manner consistent with the standards governing such services and the provisions of this Agreement. The successful Vendor further represents and warrants that all services shall be performed by qualified personnel in a professional and workmanlike manner, consistent with industry standards, and that all services will conform to applicable specifications. The Vendor warrants that the goods to be supplied shall be merchantable, of good quality, and free from defects, whether patent or latent. The goods shall be sufficient for the purpose intended and conform to the PROPOSAL REQUEST #B2200146 Page 4 minimum specifications herein. The successful Vendor shall warrant that he has title to the goods supplied and that the goods are free and clear of all liens, encumbrances, and security interests. Service Calls in the First One Year Period: The successful Vendor shall bear all costs for mileage, travel time, and service trucks used in the servicing (including repairs) of any of the goods to be purchased by Weld County, Colorado, pursuant to this proposal for as many service calls as are necessary for the first one (1) year period after said goods are first supplied to Weld County. Vendor shall submit with their proposals the following information pertaining to the equipment upon which the proposals are submitted: 1. Detailed equipment specifications to include the warranty. 2. Descriptive literature. P. Non -Assignment: The successful Vendor may not assign or transfer this Agreement or any interest therein or claim thereunder, without the prior written approval of County. Any attempts by the successful Vendor to assign or transfer its rights hereunder without such prior approval by County shall, at the option of County, automatically terminate this Agreement and all rights of the successful Vendor hereunder. Such consent may be granted or denied at the sole and absolute discretion of County. Q. Interruptions: Neither party to this Agreement shall be liable to the other for delays in delivery or failure to deliver or otherwise to perform any obligation under this Agreement, where such failure is due to any cause beyond its reasonable control, including but not limited to Acts of God, fires, strikes, war, flood, earthquakes or Governmental actions. R. Non -Exclusive Agreement: This Agreement is nonexclusive and County may engage or use other contractors or persons to perform services of the same or similar nature. S. Employee Financial Interest/Conflict of Interest — C.R.S. §§24-18-201 et seq. and §24-50-507. The signatories to this Agreement agree that to their knowledge, no employee of Weld County has any personal or beneficial interest whatsoever in the service or property which is the subject matter of this Agreement. County has no interest and shall not acquire any interest direct or indirect, that would in any manner or degree interfere with the performance of the successful Vendor's services and the successful Vendor shall not employ any person having such known interests. During the term of this Agreement, the successful Vendor shall not engage in any in any business or personal activities or practices or maintain any relationships which actually conflicts with or in any way appear to conflict with the full performance of its o bligations under this Agreement. Failure by the successful Vendor to ensure compliance with this provision may result, in County's sole discretion, in immediate termination of this Agreement. No employee of the successful Vendor nor any member of the successful Vendor's family shall serve on a County Board, committee or hold any such position which either by rule, practice or action nominates, recommends, supervises the successful Vendor's operations, or authorizes funding to the successful Vendor. T. Severability: If any term or condition of this Agreement shall be held to be invalid, illegal, or u nenforceable by a court of competent jurisdiction, this Agreement shall be construed and enforced without such provision, to the extent that this Agreement is then capable of execution within the original intent of the parties U. Binding Arbitration Prohibited: Weld County does not agree to binding arbitration by any extra- judicial body or person. Any provision to the contrary in the contract or incorporated herein by reference shall be null and void. V. Board of County Commissioners of Weld County Approval: This Agreement shall not be valid u ntil it has been approved by the Board of County Commissioners of Weld County, Colorado or its designee. W. Compensation Amount: Upon the successful Vendor's successful completion of the service, and County's acceptance of the same, County agrees to pay an amount no greater than the amount of the accepted proposal. The successful Vendor acknowledges no payment in excess of that amount will be made PROPOSAL REQUEST #B2200146 Page 5 by County unless a "change order" authorizing such additional payment has been specifically approved by the County's delegated employee, or by formal resolution of the Weld X Taxes County Board of County Commissioners, as required pursuant to the Weld County Code County will not withhold any taxes from monies paid to the successful Vendor hereunder and the successful Vendor agrees to be solely responsible for the accurate reporting and payment of any taxes related to payments made pursuant to the terms of this Agreement Contractor shall not be entitled to bill at overtime and/or double time rates for work done outside of normal business hours unless specifically authorized in writing by County 6 INSURANCE REQUIREMENTS Insurance and Indemnification Contract Professionals must secure, at or before the time of execution of any agreement or commencement of any work, the following insurance covering all operations, goods or services provided pursuant to this request Contract Professionals shall keep the required insurance coverage in force at all times during the term of the Agreement, or any extension thereof, and during any warranty period The required insurance shall be underwritten by an insurer licensed to do business in Colorado and rated by A M Best Company as "A" VIII or better Each policy shall contain a valid provision or endorsement stating "Should any of the above -described policies by canceled or should any coverage be reduced before the expiration date thereof, the issuing company shall send written notice to the Weld County Controller by certified mail, return receipt requested Such written notice shall be sent thirty (30) days prior to such cancellation or reduction unless due to non-payment of premiums for which notice shall be sent ten (10) days prior If any policy is in excess of a deductible or self -insured retention, County must be notified by the Contract Professional Contract Professional shall be responsible for the payment of any deductible or self - insured retention County reserves the right to require Contract Professional to provide a bond, at no cost to County, in the amount of the deductible or self -insured retention to guarantee payment of claims The insurance coverages specified in this Agreement are the minimum requirements, and these requirements do not decrease or limit the liability of Professional The County in no way warrants that the minimum limits contained herein are sufficient to protect them from liabilities that might arise out of the performance of the work under this Contract by the Contract Professional, its agents, representatives, employees, or subcontractors The Contract Professional shall assess its own risks and if it deems appropriate and/or prudent, maintain higher limits and/or broader coverages The Contract Professional is not relieved of any liability or other obligations assumed or pursuant to the Contract by reason of its failure to obtain or maintain insurance in sufficient amounts, duration, or types The Contract Professional shall maintain, at its own expense, any additional kinds or amounts of insurance that it may deem necessary to cover its obligations and liabilities under this Agreement Any modification to these requirements must be made in writing by Weld County The Contract Professional stipulates that it has met the insurance requirements identified herein The Contract Professional shall be responsible for the professional quality, technical accuracy, and quantity of all services provided, the timely delivery of said services, and the coordination of all services rendered by the Contract Professional and shall, without additional compensation, promptly remedy and correct any errors, omissions, or other deficiencies INDEMNITY. The Contract Professional shall defend, indemnify and hold harmless County, its officers, agents, and employees, from and against injury, loss damage, liability, suits, actions, or willful acts or omissions of Contract Professional, or claims of any type or character arising out of the work done in fulfillment of the terms of this Contract or on account of any act, claim or amount arising or recovered under workers' compensation law or arising out of the failure of the Contract Professional to conform to any statutes, ordinances, regulation, law or court decree The Contract Professional shall be fully responsible and liable for any and all injuries or damage received or sustained by any person, persons, or property on account of its performance under this Agreement or its failure to comply with the provisions of the Agreement, or on account of or in consequence of neglect of the Contract Professional in its methods or procedures, or in its provisions of the materials required herein, or from any claims or amounts arising or recovered under the Worker's Compensation Act, or other law, ordinance, order, or decree This paragraph shall survive expiration or termination hereof It is agreed that the Contract Professional will be responsible for primary loss investigation, defense and judgment costs where this contract of indemnity applies In consideration of PROPOSAL REQUEST teAlad Page 6 the award of this contract, the Contract Professional agrees to waive all rights of subrogation against the County its associated and/or affiliated entities, successors, or assigns, its elected officials, trustees, employees, agents, and volunteers for losses arising from the work performed by the Contract Professional for the County. A failure to comply with this provision shall result in County's right to immediately terminate this Agreement. Types of Insurance: The Contract Professional shall obtain, and maintain at all times during the term of any Agreement, insurance in the following kinds and amounts: Workers' Compensation Insurance as required by state statute, and Employer's Liability Insurance covering all of the Contract Professional's employees acting within the course and scope of their employment. Policy shall contain a waiver of subrogation against the County. This requirement shall not apply when a Contract Professional or subcontractor is exempt under Colorado Workers' Compensation Act., AND when such Contract Professional or subcontractor executes the appropriate sole proprietor waiver form. Commercial General Liability Insurance shall include bodily injury, property damage, and liability assumed under the contract. $1,000,000 each occurrence; $1,000,000 general aggregate; $1,000,000 Personal Advertising injury Automobile Liability: Contract Professional shall maintain limits of $1,000,000 for bodily injury per person, $1,000,000 for bodily injury for each accident, and $1,000,000 for property damage applicable to all vehicles operating both on County property and elsewhere, for vehicles owned, hired, and non -owned vehicles used in the performance of this Contract. Professional Liability (Errors and Omissions Liability) The policy shall cover professional misconduct or lack of ordinary skill for those positions defined in the Scope of Services of this contract. Contract Professional shall maintain limits for all claims covering wrongful acts, errors and/or omissions, including design errors, if applicable, for damage sustained by reason of or in the course of operations under this Contract resulting from professional services. In the event that the professional liability insurance required by this Contract is written on a claims -made basis, Contract Professional warrants that any retroactive date under the policy shall precede the effective date of this Contract; and that either continuous coverage will be maintained or an extended discovery period will be exercised for a period of two (2) years beginning at the time work under this Contract is completed. Minimum Limits: Per Loss Aggregate $ 1,000,000 $ 2,000,000 Contract Professionals shall secure and deliver to the County at or before the time of execution of this Agreement, and shall keep in force at all times during the term of the Agreement as the same may be extended as herein provided, a commercial general liability insurance policy, including public liability and property damage, in form and company acceptable to and approved by said Administrator, covering all operations hereunder set forth in the related Proposal. Proof of Insurance: County reserves the right to require the Contract Professional to provide a certificate of insurance, a policy, or other proof of insurance as required by the County's Risk Administrator in his sole discretion. Additional Insureds: For general liability, excess/umbrella liability, pollution legal liability, liquor liability, and inland marine, Contract Professional's insurer shall name County as an additional insured. Waiver of Subrogation: For all coverages, Contract Professional's insurer shall waive subrogation rights against County. PROPOSAL REQUEST #B2200146 Page 7 Subcontractors All subcontractors, independent Contract Professionals, sub -vendors, suppliers or other entities providing goods or services required by this Agreement shall be subject to all of the requirements herein and shall procure and maintain the same coverages required of Contract Professional Contract Professional shall include all such subcontractors, independent Contract Professionals, sub -vendors suppliers or other entities as insureds under its policies' or shall ensure that all subcontractors maintain the required coverages Contract Professional agrees to provide proof of insurance for all such subcontractors, independent Contract Professionals, sub -vendors suppliers or other entities upon request by the County The terms of this Agreement are contained in the terms recited in this Request for Proposal and in the Response to the Proposal each of which forms an integral part of this Agreement Those documents are specifically incorporated herein by this reference PROPOSAL REQUEST Page 8 PROPOSAL SPECIFICATIONS SUMMARY OF INTENT/INTRODUCTION Weld County (the "county") is seeking proposals from investment advisors to provide portfolio management services that are described herein. This will be a one-year contract with options for four one-year renewals. The initial contract period is expected to begin within the fourth quarter of 2022, immediately after execution of the contract. Services are being solicited for the county's pooled portfolio. Presently the county maintains a pooled portfolio of approximately $600 million. Of this amount, approximately $400-$450 million is expected to be under the portfolio management services of the investment advisor. The remaining funds are short-term in nature and will continue to be internally managed. Respondents should understand that the present size of the portfolio may increase or decrease due to normal operations and/or decisions made relative to the timing of capital projects. We are seeking an investment advisor who demonstrates extensive experience in providing services related to the investment of county funds. These services include, but are not limited to, executing securities purchases/sales for the county's portfolio, offering investment advice, and preparing regular investment reports. All services shall be performed in accordance with Colorado State law and the county's investment ordinance, policies, and procedures. BACKGROUND Weld County is home to 32 incorporated municipalities, including growing cities, charming towns, thriving businesses, and thousands of acres of prime agricultural land. Agriculture and oil and gas are two very important industries in Weld County. The county seat and principal city, Greeley, is located in the west central part of the county and contains almost half of the county's population. As Colorado's third largest county, the county covers 3,987 square miles in the northern part of the state and is larger than the size of Rhode Island, Delaware and the District of Columbia combined. While 333,000 people call Weld County home, there is still plenty of room for growth. Weld County became Colorado's first Home Rule County in 1976. The County is governed by a five -member Board of County Commissioners. Three Commissioners are elected by districts of relatively equal population and two Commissioners are elected at large. Each Commissioner coordinates one of the five functions of the County and, therefore, there is no County Administrator. The County also is served by four Elected Officials: Assessor, Clerk and Recorder, District Attorney, and Sheriff. Unlike other Colorado counties the Weld County Treasurer is appointed and not elected. The investment of county funds is governed by the County Charter and Colorado State law. The county currently utilizes internal staff to manage its investment portfolio. Copies of the current investment policy (Attachment A), county code (Attachment B), and the portfolio list (Attachment C) are attached to this RFP. MINIMUM SERVICE REQUIREMENTS The investment advisor shall work with the county to develop an investment strategy that meets the objectives below in the following order of importance: • Protects the principal invested within the county's portfolio; and • Maintains sufficient liquidity of the portfolio to provide for the cash needs of the county; and • Maximizes the return on investment within the county's portfolio. The county has the expectation that the investment advisor will provide services including, but not limited to, the following: PROPOSAL REQUEST #B2200146 Page 9 Be either completely independent of any financial institution or securities brokerage firm, or fully and continuously disclose any relationships with such financial institution(s) and/or securities brokerage firm(s), and further disclose any commissions, bonuses, or soft -dollar payments resulting from the firm's relationship with the county 2 Take no possession of the county's moneys or investment securities, nor have access to or control over such moneys and/or securities The investment advisors WILL NOT provide custodial services or security safekeeping 3 Comply with Colorado State law and the code and policies of the county 4 Provide non -discretionary and/or discretionary management of the county's investment portfolios by acting in an advisory and administrative capacity within the guidelines of Weld County's Investment Policy (The county will make a decision about the type of management after discussion with the selected firm regarding benefits and challenges of each approach ) 5 Assist in all aspects of investment portfolio management including initiating securities purchases/sales upon written instructions from authorized county staff for the pooled portfolio After a trade is executed, the advisor must confirm to the county via email all details of the trade including the dealers contacted and the prices received 6 Review and recommend changes to the county's investment policy and ordinance and current investment management procedures and documentation 7 Assist in developing and implementing investment strategies that will enhance portfolio performance under current and anticipated changes in market conditions within the parameters of established investment policies and cash flow needs Make presentations to the county's Investment Committee, as needed, to support recommendations relating to investment strategy 8 Provide timely assessments of the market including market reaction to economic events 9 Provide credit and risk management analysis of investment instruments to be used in the portfolio 10 Work with county staff to develop cash flow projections to ensure that the investment strategy is consistent with the county's cash requirements and provide recommendations of change 11 Provide ongoing technology enhancement recommendations for portfolio management, cash flow forecasting, and daily investment activities 12 Establish appropriate benchmarks 13 Provide online access to county investment portfolio reports on earnings performance and trend analysis 14 Provide monthly statements on investment activity, earnings, and the value of the investment portfolio For the county's year end reporting, these reports must include a mark -to -market valuation and fair value measurement as required by Governmental Accounting Standards Board (GASB) 40 and 72 These reports must also provide monthly information related to the diversity of investments and compliance with applicable Colorado State laws and county policies 15 Provide quarterly investment reports including a description of market conditions, investment strategies employed, and performance The performance numbers shall be presented as required by the county's policies If requested, attend Investment Committee meetings to present quarterly/annual results, along with market commentary and future outlook as it pertains to the county's portfolio PROPOSAL REQUEST # ? IGIN Page 10 16. Provide ongoing "best practices" recommendations. TERM OF CONTRACT The county intends to enter into a one-year contractual agreement commencing sometime fourth quarter 2022, with an option for an additional four one-year extensions to be exercised at the sole discretion of the county. PROPOSAL CONTENT Your written proposal should include the information in the format outlined below. Please limit your response to no more than 75 pages. All proposals shall be submitted in the order described herein. Supplemental information requested shall be submitted in writing to the county by the date specified in this RFP. We recommend that you include concise, but complete information about your firm, emphasizing why you believe your firm to be uniquely qualified for this operation. As mentioned above, short listed firms may be required to attend a formal, in person interview and/or make an oral presentation to the evaluation committee. To facilitate comparisons between responding firms, please format your response to this request in the following order: 1. ORGANIZATION 1.1. Describe the organization, date founded, number of employees, location of your firm's offices, and ownership of your firm as well as any subsidiaries and affiliates relevant to the county. 1.2. Describe your firm's core mission, vision, and values. 1.3. Identify the types of accounts primarily sought by your firm. 1.4. Describe the experience of the firm in serving as investment advisor for counties and other public entities. Please cite specific instances of portfolios managed and include dollar volume in the portfolio. Identify the individuals from the firm who had principal responsibility for the account. 1.5. Does your firm act as a broker or primary securities dealer? Other than direct fees paid by clients, does your firm receive any other form of additional compensation (including soft dollars) for client transactions? 1.6. Please describe the financial condition of your firm, parent, or affiliate. Within the past five years, have there been any changes in ownership or restructuring? If anticipated, describe any future, significant changes to your firm. 1.7. Provide a copy of your firm's most recent annual audited financial statements. 1.8. Discuss your firm's assessment of the current market outlook and how your firm plans to provide superior performance for clients in the years ahead. 1.9. Describe why accounts/clients, if any, have dropped the firm in the past five years. 1.10. Within the past ten years, has your organization or an officer or principal been involved with any business litigation, SEC or regulatory censure, or other legal proceedings related to your consulting activities? Please provide details with respect to the current status or disposition. PROPOSAL REQUEST #B2200146 Page 11 1 11 Please disclose any potential conflicts of interest 2 PERSONNEL 21 Identify the size of the firm's staff commitment to the public sector 22 Provide an organization chart showing your proposed project team to provide the services required in this RFP, including analytical investment and research staff and back -office support Please identify the primary contact and describe the role of the primary contact and of each key person on the team How do you provide back up if the primary contact person is unavailable? 23 Provide summary biographies and/or resumes of individuals who would be providing investment advisory services to the county, including professional designations and/or licenses For each individual describe their proposed role (including proposed time commitment) and list their relevant experience and substantive areas of expertise 24 Have any of the above personnel ever been investigated for alleged improper, fraudulent, or unfair activities related to the sale of securities? If so, please provide details 25 State whether there has been any turnover of key personnel in the firm or additions to staff in the past two years 26 What efforts does your firm make to keep its investment professionals informed of developments relevant to government investment managers? 27 Identify your firm's compensation arrangement for professional staff Describe any circumstances under which your firm or any consultant in your firm receives compensation or finder's fees from investment managers Provide copies of your conflict of interest, and code of conduct policies 3 INVESTMENT MANAGEMENT APPROACH 31 Describe your anticipated role and what specific services you would provide as investment advisor Does your firm have the capability of soliciting competitive bids on investment purchases? 32 Describe the level of involvement you anticipate with county staff and what information you require from county staff on a daily, monthly, or other basis to execute investment advisory responsibilities (e g , confirmation of cash projections, receipt of new monies, and knowledge of pending county funding requirements) Describe the daily procedures for portfolio review and client contact 33 Briefly describe your firm's investment management philosophy Provide specific detail on how it will apply to managing governmental and yield -based portfolios What are your primary strategies for adding value? 34 What is your firm's experience in developing investment policies, internal procedures, and portfolio strategies for public sector clients? 35 Describe the types of investment research utilized and the methods for making investment decisions, including maturity and selection Describe your firm's in-house research capabilities Do you use outside sources regularly? Describe your credit review process Do you assign credit PROPOSAL REQUEST Page 12 research to specialists? What percentage of your research is conducted in-house? Describe your firm's research capability. 3.6. Discuss your prognosis of interest rates (both short and long-term) over the next two years and the investment strategy you would currently recommend for the county over the next two years. Briefly discuss investment alternatives available to the county currently on the market in terms of rate of return and relative risks. 3.7. Provide performance data for similar accounts under management with comparative industry performance data for the last year, five-year, and ten- year period. Please show annualized quarterly returns, gross of all management fees. All performance numbers must be presented in accordance with the APT US&C. 4. REPORTING 4.1. Describe the investment accounting and reporting system used, including your on-line reporting capabilities. 4.2. Describe your firm's knowledge of and ability to assist in the compliance with GASB 40 and 72. 4.3. Describe the process the firm would go through to assist in identifying appropriate benchmarks. Based on your experience, what performance benchmark would you suggest for the county's portfolios given the current investment policy requires a short-term and a long-term benchmark? 4.4. Describe the performance measurement software your firm uses and what type of information would be included with the performance reports. Is this software proprietary, or does your firm utilize the software of an outside vendor? If your firm uses non-proprietary software, do you have the ability to influence changes to the software to meet the demands of the marketplace? 4.5. Describe and submit samples of the reports that would be provided and their frequency. (Please include the methods and formulas used to calculate yield and performance). 4.6. How soon after the month -end and quarter -end are your reports typically available? 5. FEES 5.1. Describe the proposed compensation for services as a flat annual fee and/or as a fee calculated based upon the dollar value of assets managed. The County's preference would be a flat annual fee but is open to other fee structures. Also describe any cap or maximum or minimum limit to the fee. 5.2. Identify any expenses that would not be covered through this fee structure and would be required in order to implement the firm's program. 5.3. If hired, will your firm receive any other form of compensation, including soft dollars, from working with this account that has not yet been received? If so, what is the form of compensation? 6. REFERENCES 6.1. Provide a list of five comparable public sector clients with portfolio size similar to the county, including contact persons and telephone numbers. PROPOSAL REQUEST #B2200146 Page 13 7. OTHER CONSIDERATIONS 7 1 Describe how a new client would transition to your services 7 2 Describe the firm's approach to managing relationships with the broker/dealer community 7 3 Describe any assistance the firm would provide in reviewing custodial and safekeeping arrangements 7 4 Describe any other services that the firm believes may be of value to the county 7 5 Describe the aspects of your firm that distinguish it from competitors EVALUATION PROCESS 1 INITIAL REVIEW All proposals will be initially evaluated to determine if they meet the following minimum requirements • The proposal must be complete, in the required format, and be in compliance with all the requirements of the RFP, and • The respondent must meet the Minimum Service Requirements outlined in that section of this RFP 2. TECHNICAL REVIEW An evaluation committee will evaluate proposals submitted The evaluation committee will use a 100 -point formula during the review process to score proposals to determine an overall rank for each respondent Each member of the evaluation committee will review the submitted proposals and score points as provided in the scoring guidelines Proposals meeting the above requirements will be evaluated on the basis of the following criteria • Understanding of the services required by the county, Quality and responsiveness of the proposal, Ability to present a clear understanding of the nature and scope of the project clearly and succinctly, • Demonstrated competence and professional qualifications, • Recent experience in successfully performing similar services, • Proposed approach in completing the services, • References, • Qualifications and experience of specific personnel assigned to this project, and • Proposed cost to the county 3 INTERVIEW/ORAL PRESENTATION At the discretion of the evaluation committee, some or all respondents who submit a proposal may be asked to submit to an interview or give an oral presentation of their respective proposals to the evaluation committee If so, this is not to be a presentation restating the proposal, but rather an in- depth analysis of certain qualifications of the respondent If the interview/oral presentations are conducted, they will also be scored The evaluation committee may request Best and Final Offers/revisions to the proposal from each of the respondents at the conclusion of the interviews/oral presentations if deemed necessary Respondents who are requested to submit Best and Final offers/revisions will be scored accordingly All travel expenses to and from the interview or oral presentation shall be the responsibility of the respondent PROPOSAL REQUEST #MR- Page 14 CONTRACT AWARD The county reserves the right to award this contract not necessarily to the firm with the most advantageous price, but to the firm that demonstrates the overall best value to the county in terms of ability and overall cost. The county will select the most qualified firm, and a contract prepared by the county will be negotiated with the successful service provider. In the event a contract cannot be negotiated with the top ranked firm, the county may enter into negotiations with the second highest ranked firm or the county may decide to call for new proposals. Immediately after the notice of award, the contractor will begin planning, in conjunction with county staff, to insure fulfillment of all its obligations. Attachment A: Investment Policy Approved 2021 Attachment B: Weld County Code Article XI, Section 11.4 Investment of Funds Attachment C: Weld County Investments as of Sept 14, 2022 PROPOSAL SUBMITTAL INSTRUCTIONS: The following items must be completed and submitted with your proposal opening deadline of 10:00 AM on October 19, 2022: 1) Pages 9 thru 16 of the Proposal Specifications/Scope of Work. 2) W9, if applicable* 3) Any future Addenda must be completed. 4) All other items as requested in the Scope of Work. on or before the proposal *A current W9 is required for new Vendors. If you have previously worked with Weld County, only provide your W9 if there has been a change. Failure to include any of the above items upon submittal of your proposal may result in your proposal being incomplete and your proposal being rejected. If there are any exclusions or contingencies submitted with your proposal it may be disqualified. PROPOSAL REQUEST #B2200146 Page 15 The undersigned, by his or her signature, hereby acknowledges and represents that: 1. The proposal proposed herein meets all of the conditions, specifications and special provisions set forth in the Request for Proposal for Request No. #B2200146. 2. The quotations set forth herein are exclusive of any federal excise taxes and all other state and local taxes 3. He or she is authorized to bind the below -named Vendor for the amount shown on the accompanying proposal sheets. 4. The signed proposal submitted, all of the documents of the Request for Proposal contained herein (including, but not limited to product specifications and scope of services), and the formal acceptance of the proposal by Weld County, together constitutes a contract, with the contract date being the date of formal acceptance of the proposal by Weld County. 5. Weld County reserves the right to reject any and all proposals, to waive any informality in the proposals, and to accept the proposal that in the opinion of the Board of County Commissioners, is in the best interest of Weld County. The proposal(s) may be awarded to more than one vendor. FIRM BY BUSINESS ADDRESS CITY, STATE, (Please print) DATE ZIP CODE TELEPHONE NO FAX TAX ID # SIGNATURE E-MAIL WELD COUNTY IS EXEMPT FROM COLORADO SALES TAXES. THE CERTIFICATE OF EXEMPTION NUMBER IS #98-03551-0000. ATTEST: Weld County Clerk to the Board BY: YOU DO NOT NEED TO SEND BACK PAGES 1 - 8. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO Deputy Clerk to the Board Scott K. James, Chair APPROVED AS TO SUBSTANCE: Elected Official or Department Head Controller PSRFP0922 PROPOSAL REQUEST #B2200146 Page 16 ATTACHMENT A RESOLUTION RE: APPROVE WELD COUNTY INVESTMENT POLICY AND AUTHORIZE CHAIR AND CHAIR PRO-TEM TO SIGN WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, the Board has been presented with an Investment Policy for the County of Weld, Colorado, State of Colorado, by and the through the Board of County Commissioners of Weld County, on behalf of the Treasurer's Office, with further terms and conditions being as stated in said investment policy, and WHEREAS, after review, the Board deems it advisable to approve said investment policy, a copy of which is attached hereto and incorporated herein by reference. NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that the Investment Policy for the County of Weld, State of Colorado, by and through the Board of County Commissioners of Weld County, on behalf of the Treasurer's Office, be, and hereby is, approved. BE IT FURTHER RESOLVED by the Board that the Chair and Chair Pro-Tem be, and hereby are, authorized to sign said investment policy. The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 8th day of November, A.D., 2021. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST: dj,o;tk, EXCUSED Stev- oreno, Chair Weld County Clerk to the Board BY: APP County - ttorney Date of signature I I f i 5/2-I mes, Pr Perry L. ck XCUSED ike Fr Lori Sai cc:TRWM), ACT( °),f w/S4 la/03 /,21 2021-3112 TR0030 WELD COUNTY INVESTMENT POLICY 2021 I. INTRODUCTION Section 6-1 of the Weld County Home Rule charter was amended by the Weld County voters on November 8, 2001, making the office of County Treasurer appointed by the Board of Weld County Commissioners, effective January 1, 2003. In order to fulfill their fiduciary responsibilities concerning the Treasurer's investments the Board of Weld County Commissioners decided that an oversight committee, known as the Investment Advisory Committee, should be created which includes the Treasurer, the Director of Finance and Administration, CFO, the Controller, the Chair, and Chair Protem of the Board of Weld County Commissioners. This Investment Policy replaces any previous Investment Policy or Investment Procedures of Weld County. The investment guidelines outlined below have been written to comply with various regulatory requirements under which Weld County operates. This Investment Policy was endorsed and recommended for adoption by the Weld County Investment Advisory Committee October 2021. II. SCOPE The following investment policy addresses the methods, and procedures to ensure effective and judicious fiscal and investment management of the County's funds. This policy shall apply to the investment management of all financial assets and funds under control of the County except for its employee retirement system fund, which is organized and administered separately by the Weld County Retirement Board. These investment transactions/activities are accounted for in the government's annual financial report and include the following: • General fund, • Special Revenue funds, • Debt Service funds. • Capital Projects funds, • Enterprise fund, • Internal Service funds, • Trust and Agency funds - Expendable Trust funds & Agency funds, and • Any new fund created by the governing body, unless specifically exempted by the governing body 2021-3112 III. INVESTMENT OBJECTIVES All funds which are held for future disbursement shall be deposited and invested by the County in accordance with Colorado State Statutes and ordinances and resolutions enacted by the Board of Weld County Commissioners in a manner to accomplish the following objectives: 1. Safety of Funds: Safety of principal is the foremost objective of the investment program. Investments shall be undertaken in a manner that seeks to ensure the preservation of capital in the overall portfolio. The objective will be to mitigate credit risk and interest rate risk. A. Credit Risk. The County will minimize credit risk, the risk of loss due to the failure of the security issuer, by: a. Limiting investments to the safest types of securities; b. Pre -qualifying the financial institutions, broker/dealers, and advisors with which the County does business, and c. Diversifying the investment portfolio so that potential losses on individual securities will be minimized. B. Interest Rate Risk: The County will minimize the risk that the market value of securities in the portfolio will fall due to changes in general interest rates by: a. Structuring the investment portfolio so that securities mature sufficiently close to cash requirements for ongoing operations, thereby minimizing the potential need to sell securities on the open market prior to maturity and b. Investing operating funds primarily in short- to intermediate -term securities, approved local government investment pools, approved money market mutual funds and repurchase agreements. 2. Liquidity of Funds: The investment portfolio shall remain sufficiently liquid to meet all operating requirements that may be reasonably anticipated. To ensure that adequate funds are available to pay the County's projected financial obligations, investments will be purchased that reasonably match the anticipated cash disbursements of the County. Since all possible cash demands cannot be anticipated, the portfolio shall consist largely of securities with active secondary or resale markets so that the potential for a realized loss, if an early liquidation of a security is necessary, can be minimized. A core of stable funds may be identified through cash flow analysis that is available for investing in longer -term securities. Although the market value of these longer term securities may fluctuate significantly, the fluctuation will not affect the liquidity of the portfolio since they can be held to maturity in all but extreme circumstances. 3. Yield: The County's portfolio shall earn a competitive market rate of return on available funds throughout budgetary and economic cycles. In meeting this objective, investment management personnel will take into account the County's investment risk constraints and cash flow needs. The County's overall investment program shall be designed and managed with a degree of professionalism that is worthy of the public trust. The County recognizes that no investment is totally free of risk and that the investment activities of the County are a matter of public record. Accordingly, the County recognizes that occasional measured losses are inevitable in a diversified portfolio and shall be considered within the context of the overall portfolio's return, provided that this policy has been followed and that the sale of a security prior to maturity is in the best long-term interest of the County. IV. DELEGATION OF AUTHORITY Authority to manage the investment program is granted to the Treasurer derived from Article 11 of the Weld County Home Rule Charter. Responsibility for the operation of the investment program is hereby delegated to the Treasurer, who shall carry out established written procedures and internal controls for the operation of the investment program consistent with this investment policy. Procedures shall include references to: safekeeping, delivery vs. payment, investment accounting, repurchase agreements and banking services contracts. No person may engage in an investment transaction except as provided under the terms of this policy and the procedures established by the Treasurer. The Treasurer shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials. The Treasurer may engage the support services of outside professionals, so long as it can be demonstrated that these services produce a net financial advantage and necessary financial protection of the County's resources. Such services may include engagement of financial advisors in conjunction with debt issuance, portfolio management support, special legal representation, third party custodial services, and appraisal of independent rating services. V. PRUDENCE AND INDEMNIFICATION The standard of prudence, as defined by the Colorado Revised Statutes, to be used for managing the County's assets is the "prudent investor" rule applicable to a fiduciary, which states that a prudent investor "shall exercise the judgment and care, under circumstances then prevailing, which men of prudence, discretion, and intelligence exercise in the management of the property of another, not in regard to speculation but in regard to the permanent disposition of funds, considering the probable income as well as the probable safety of their capital" (CR5 15-1-304, Standard for Investments.) The Director of Finance, Treasurer and other authorized persons acting in accordance with written procedures and exercising due diligence shall be relieved of personal responsibility for an individual security's credit risk or market price changes provided deviations from expectations are reported in a timely fashion and the liquidity and the sale of securities are carried out in accordance with the terms of this policy. The Treasurer will be responsible for ensuring that sufficient liquidity exists to maintain the County's operations in the event of adverse market conditions or claims. VI. ETHICS AND CONFLICTS OF INTEREST As noted in Section 16-9 (2) (b) of the Weld County Home Rule Charter: "Neither the Treasurer nor employees of the Treasurer's Office shall have any proprietary interest in any financial institution in which the County maintains deposits." VII. ELIGIBLE INVESTMENTS AND TRANSACTIONS All investments will be made in accordance with the Colorado Revised Statutes (CRS) as follows CRS 11-10.5-101, et seq. Public Deposit Protection Act, CRS 11-47.101, et seq. Savings and Loan Association Public Deposit Protection Act; CRS 11-60-101, et seq. U.S. Agency Obligations; CRS 24-75-601, et seq. Funds -Legal Investments for Governmental Units; CRS 24-75-603, et seq. Depositories; and CRS 24-75-701, et seq. Local Governments -Local Government Pooling. Any revisions on extensions of these sections of the CRS will be assumed to be part of this policy immediately upon being enacted. This investment policy further restricts the investment of County funds to the following types of securities and transactions: A. Treasury Obligations: Treasury bills, Treasury notes, Treasury bonds and Treasury STRIPS with maturities not exceeding five years from the date of purchase. B. Federal Instrumentality Securities: Debentures, discount notes, global securities, callable securities and stripped principal on coupons with maturities not exceeding five (5) years from the date of purchase issued by the following only: Federal National Mortgage Association (FNMA), Federal Farm Credit Banks (FFCB), Federal Home Loan Banks (FHLB), Federal Home Loan Mortgage Corporation (FHLMC. For the purposes of this paragraph, a `weighted average life" will not constitute a stated final maturity. C. Repurchase Agreements with a defined termination date of 180 days or less collateralized by U. S. Treasury and agency securities listed in item 1 and 2 above with a maturity not exceeding 10 years. Title must transfer to the County of Weld or the County must have a perfected security interest. For the purpose of this section, the term "collateral' shall mean "purchased securities" under the terms of the County's approved Master Repurchase Agreement. The purchased securities shall have a fixed coupon rate and an original minimum market value including accrued interest of 102 percent of the dollar value of the transaction and the collateral maintenance level shall be 102 percent. Collateral shall be held in the County's custodial bank as safekeeping agent, and the market value of the collateral securities shall be marked -to -the -market daily based on that day's bid price. Repurchase Agreements shall be entered into only with dealers who have executed a Master Repurchase Agreement with the County and who are recognized as Primary Dealers with the Market Reports Division of the Federal Reserve Bank of New York. Approved counterparties to repurchase agreements shall have at least a short-term debt rating of A-1 or the equivalent and a long-term debt rating of A or the equivalent from one on more nationally recognized organizations which regularly rates such obligations. D. Local Government Investment Pools authorized under CRS 24-75-701, 702 which are managed to a stable value (usually $1 per share). E. Certificates of Deposit or savings accounts in state or national banks or in state or federally chartered savings and loans that are state approved depositories per CR5 24-75-603, et seq. (as evidenced by the State Banking Board) and are insured by the FDIC. Certificates of deposit which exceed the FDIC insured amount shall be collateralized in accordance with the Colorado Public Deposit Protection Act. [Allow CD purchases up to the FDIC limit in US banks outside of Colorado.] F. Negotiable Certificates of Deposit (CDs with a CUSIP number) must meet the same rating and maturity requirements for debt securities under item F below. G. Corporate or Municipal Debt that does not exceed five (5) years in maturity at the time of purchase with a AAA raring; or does not exceed three (3) years in maturity at the time of purchase if it is AA rated. H. Commercial Paper in accordance with Colorado State statutes in 24-75-603. I. Money Market Mutual Funds registered under the Investment Company Act of 1940 that meet Federal Securities Regulation 2A-7 standards. Any deviation from this list must be pre -approved by the Board of Weld County Commissioners in writing. VIII. INVESTMENT DIVERSIFICATION It is the intent of the County to diversify the investments in the portfolio to avoid incurring unreasonable risks inherent in over -investing in specific instruments, individual financial institutions or maturities. The asset allocation in the portfolio should, however, be flexible depending upon the outlook for the economy, the securities market, and the County's anticipated cash flow needs. A minimum of 50% of the investment assets of the County will be maintained in those securities listed in items A, B, C, D, and H under Eligible Investments and Transactions. IX. INVESTMENT MATURITY AND LIQUIDITY Investments shall be limited to maturities not exceeding five (5) years unless otherwise approved in writing by the Board of Weld County Commissioners for special circumstances (e.g., the reinvestment of bond proceeds). The County shall maintain at least 10% of its total investment portfolio in instruments maturing in 90 days or less. X. COMPETITIVE TRANSACTIONS Each investment transaction shall be competitively transacted with broker/dealers who have been authorized by the County. Securities shall be purchased at the then best offering price based on the market conditions at that time. XL SELECTION OF BROKER/DEALERS AND FINANCIAL INSTITUTIONS ACTING AS BROICER/ DEALERS AND FINANCIAL INSTITUTIONS PROVIDING INVESTMENT SERVICES. The Treasurer shall maintain a list of authorized broker/dealers and financial institutions which are approved for investment purposes, and it shall be the policy of the County to purchase securities only from those authorized institutions and firms. To be eligible, a firm/investment bank, bank, or savings and loan institution must meet at least one of the following criteria: 1. Meet the securities dealer's capital adequacy requirements of the New York Federal Reserve Bank. The capital requirements are found in the New York Federal Reserve Bank publication entitled, Capital Adequacy Guidelines for Governmental Securities Dealers, or 4. Be an FDIC member and be listed as an "Eligible Public Depository" as prepared by the State Banking Board for banks and for Savings and Loans to be approved as an "Eligible Public Depository" by the Colorado division of Financial services. Broker/dealers and other financial institutions will be selected by the Treasurer on the basis of their expertise in public cash management and their ability to provide service to the County's account. Each investment firm authorized by the Treasurer shall be a FINRA reporting broker/dealer. Broker/Dealers shall also attest in writing that they have received a copy of this policy. A list of approved Broker/Dealers, Banks, and Savings & Loan institutions is included in various "Resolutions" performed by the Board of County Commissioners of Weld County, Colorado. XII. SELECTION OF BANKS AND SAVINGS AND LOANS (DESIGNATION UNDER CRS 11-10.5-106 (Banks) and CRS.11-47-105 (Savings & Loan)) AS DEPOSITORIES AND PROVIDERS OF GENERAL BANKING SERVICES AND ASSET POOLS AS DEPOSITORIES The Treasurer shall maintain a list of authorized banks, savings and loans, and public asset pools as depositories for Weld County funds which are approved by the Board of Weld County Commissioners by resolution per CRS 30-10-708 to provide depository and other banking services for the County. To be eligible for authorization, a bank is required to be designated an eligible public depository by the state banking board and a savings and loan must be designated an eligible public depository by the state commissioner of Banking. Additionally, banks or savings and loans, in the judgment of the Treasurer, who no longer offer adequate safety or service to the County, will be removed from the approved list. The list will be updated annually if any changes are requested to insure compliance. Depositories shall be selected based on ratings and competitive rates of return. XIII. SAFEKEEPING AND CUSTODY The Treasurer shall approve one or more financial institutions to provide safekeeping and custodial services for the County. A County approved Safekeeping Agreement shall be executed with each custodian bank prior to utilizing that bank's safekeeping services. To be eligible for designation as the County's safekeeping and custodian bank, a financial institution shall meet the following criteria: 1. Have a Bauer rating of 3 stars or better out of possible 5 -star rating or 2. Have a PMA Financial Network, Inc. overall rating of three minus or better on a scale of one to five with one being the highest quality for the most recent reporting quarter before the time of selection. Custodian banks will be selected on the basis of their safety and ability to provide service to the County's account with competitive pricing of their safekeeping related services. Custodian banks shall be selected through the County's procurement process, which shall include a formal request for proposal as needed. Custodial banks should be in the highest rating categories. SAFEKEEPING All purchased securities will be perfected in the name of the County. Sufficient evidence to title shall be consistent with modern investment, banking and commercial practices. All investment securities, except non-negotiable certificates of deposit and money market funds, purchased by the County will be held by a PDPA eligible Colorado State bank or delivered by either book entry or physical delivery and will be held in third -party safekeeping by a County approved custodian bank, its correspondent New York Bank or the Depository Trust Corporation (DTC). All non -book entry (physical delivery) securities shall be held by Weld County's designated custodian bank for the benefit of the county. The County may utilize the services of the Depository Trust Corporation (DTC) as a depository for delivery of non- wireable securities. All custodies securities that are registered shall be registered in the name of the County or in the name of a nominee of the County or in the name of the custodian or its nominee or, if in a clearing corporation, in the name of the clearing corporation or its nominee. The County's custodian will be required to furnish the County with monthly reports of holdings of custody securities as well as an account analysis report of monthly securities activity. XIV. PERFORMANCE BENCHMARKS The County of Weld shall use as a goal a dynamic benchmark rate of return or the current money market rate for the County's fixed income investment portfolio that corresponds to the yield for the current money market average return expressed as an annualized basis. All fees involved with managing the portfolio should be included in the computation of the portfolio's rate of return. The Treasurer shall present to the Investment Advisory Committee of Weld County a review of the current investments and the portfolio's adherence to appropriate risk levels and a comparison between the portfolio's total return and the established investment objectives and goals. XV. REPORTING Accounting and reporting on the County's investment portfolio shall conform to Generally Accepted Accounting Principles (GAAP) and the Governmental Accounting Standards XVII. POLICY REVISIONS This investment policy shall he reviewed as needed by the Director of Finance and Treasurer and may be amended by the Investment Advisory Committee of Weld County as conditions warrant. The data contained in the annexes to this policy may be updated by the Treasurer as necessary, provided the changes in no way affect the substance or intent of this policy. Exhibit I Authorized Personnel The following persons are authorized to transact investment business and wire funds for investment purposes on behalf of the Weld County: John Lefebvre, Treasurer Rene Fielder, Assistant Treasurer INVESTMENT COMMITTEE Lefebvr reasurer ‘140,1 &142,1 Barb Connolly- C UGl�r/ on Warden — Finance Director Steve Moreno - Board Chair Sc tt K. James, Pro -Tern November 2, 2021 Date !t Date D e Da NOV 0 8 2021 Date O2 A2 ,31/ 2J ATTACHMENT B Section 11-4. Investment of Funds. (1) The County Treasurer shall, with prudence, deposit available funds in accordance with the statutes of the State of Colorado giving preference to Weld County financial institutions. (2) All interest from county funds shall become a part of the General fund, except that interest from particular funds may, by resolution of the Board, be retained in such fund. Created: 2022-08-02 18:28:35 [EST] (Supp. No. 78) Page 1 of 1 Weld County Investments (as of 9/14/22) Please note: Includes certain investments that will be managed internally (see RFP for more information) ATTACHMENT C Weld County Assets Net of Fees 9/71/207 I Call SP/Moody Rating Description Face Amt Cost Int Earned Rate YTM Settlement Mat Date Nxt Call Date Frequency Coupon Agency Amount 9/21/2022 _ CSIP CP Fund 5 20,000,000 S 20,000,000 5 328.b00 1.640 1.640 5/27/2022 9/26/2022 9/26/2022 CP Bullet 1.640 CSIP CP 20,000,000 Al CSIP CP Fund $ 10,000,000 5 10,000,000 $ 258,000 2.580 2.580 8/4/2022 10/4/2022 9/26/2022 CP Bullet 2.580 CSIP CP S 10,000,000 Al FFCB 3133EMCU4 5 10,000,000 5 10,000,000 S 19,000 0.190 0.190 7/12/2021 10/13/2022 9/21/2022 Continous 0.190 FFCB 5 10,000,000 AA/AAA CSIP CP Fund 5 5,000,000 $ 5,000,000 r_$ 79,000 1.580 1.580 3/25/2022 12/1/2022 12/1/2022 CP Bullet 1.580 CSIP CP S 5,000,000 Al FHLB 3130AQK36 $ 5,000,000 5 4,999,000 f$ 18,750 0.375 0.395 1/10/2022 1/10/2023 1/10/2023 Semi Annual 0.375 FHLB 5 4,999,000 AA/AAA Royal Bank of Canada 78014RCX6 S 10,000,000 $ 10,000,000 _ $ 3.51.10 3.511 3.511 5/22/2020 5/22/2023 5/22/2023 Qtly Feb, May, Aug, 3.511 CD RBC S 10,000,000 AA2/AA- Bank of Montreal 06367WL84 $ 10,000,000 $ 10,000,000 __$ 38.7,509 3.878 3.878 6/3/2020 6/3/2023 6/3/2023 Qtly Mar, Jun, Sep, 3.878 CD BM S 10,000,000 AA2/AA- CSIP CP Fund $ 10,000,000 $ 10,000,000 $ 292,000 2.920 2.920 6/9/2022 6/9/2023 6/9/2023 CP Bullet 2.920 CSIP CP S 10,000,000 Al FHLB 3130AN6V7 $ 20,000,000 $ 20,000,000 ;_$ 52,000 0.260 0.260 7/27/2021 10/27/2023 10/27/2022 Qtly 0.260 FHLB 20,000,000 AA2/AA- Treasury 91282CAW1 $ 25,000,000 $ 24,994,250 IS 62,500 0.250 0.260 8/27/2021 11/15/2023 11/15/2023 Bullet 0.250 UST 24,994,250 AA2/AA- FHLB 3130AMBUS $ 12,750,000 5 12,750,000 1-$ 47,813 0.375 0.375 5/17/2021 5/17/2024 8/17/2022 Qtly 0.375 FHLB 12,750,000 AA2/AA- FHLB 3130AO349 S 20,000,000 5 20,000,000 5 . 200,000 1.000 1.000 12/21/2021 6/21/2024 9/21/2022 Qtly 1.000 FHLB S 20,000,000 AA2/AA- FHLB 3130ASZG7 5 _, 10,000,000 $ - S _4O_04O00 4.000 4.000 9/16/2022 9/16/2024 12/16/2022 Qtly 4.000 FHLB S AA2/AA- Palm Beach Co FL 696572MD5 $ 5,325,000 5 5,325,000 $ 26,625 0.500 0.500 10/27/2020 10/1/2024 10/1/2024 Bullet 0.500 Palm B 5,325,000 AAA/AAA FHLB 3130ARKA8 $ -1 10,000,000 $ 10,000,000 $ 285,000 2.850 2.850 4/25/2022 10/25/2024 10/25/2022 Qtly 2.850 FHLB 10,000,000 AA/AAA FHLB 3130ANHG8 $ _20,000,000 $ 20,000,000 $ 100,000 0.500 0.500 7/30/2021 10/29/2024 10/29/2022 Qtly 0.500 FHLB 20,000,000 AA/AAA US Treasury Strips 912833LT5 $ 10,000,000 5 9,872,200 $ 39,028 0.390 0.390 7/28/2021 I 11/15/2024 11/15/2024 Bullet 0.390 USTS 9,872,200 AAA/AAA F HLMC 3134GXK86 $ 9,000,000 $ 9,000,000 $ ._360,000 4.000 4.000 8/18/2022 11/18/2024 11/18/2024 Qtly 4.000 LISTS 9,000,000 AAA/AAA FHLB 3130ANM49 $ 120,000,000 $ 20,000,000 $ 80,000 0.400 0.400 8/24/2021 12/24/2024 10/1/2024 Bullet 0.400 FHLB 5 20,000,000 AAA/AAA FHLB 313ANLR9 $ 25,000,000 s 25,000,000 $ 135,000 0.540 0.540 8/26/2021 12/26/2024 8/26/2022 Qtly 0.540 FHLB S 25,000,000 AA/AAA FHLB 3130APAJ4 $ 25,000,000 $ 25,000,000`$ 137,500 0.550 0.550 9/27/2021 12/27/2024 9/27/2022 Qtly 0.550 FHLB 5 25,000,000 AA/AAA FHLB 3130ANHH6 $ 20,000,000 5 20,000,000 $ 112,000 0.560 0.560 7/30/2021 1/29/2025 10/29/2022 Qtly 0.560 FHLB 20,000,000 AA/AAA USTN 912828ZT04 S 30,000,000 $ 29,597,306 I;$ _; 75,000 0.250 0.620 9/27/2021 5/31/2025 5/31/2025 Bullet 0.250 USTN S 29,597,306 IDC 293 FHLB 3130APL52 $ 10,000,000 $ 10,000,000 it ; 101,000 1.010 1.010 10/28/2021 7/28/2025 10/28/2022 Qtly 1.010 FHLB 5 10,000,000 AA/AAA FHLB 3130ASNU9 $ 10,000,000 $ 10,000,000 _4(15,4000 4.050 4.050 7/28/2022 7/28/2025 10/28/2022 Qtly 4.050 FHLB S 10,000,000 AA/AAA Royal Bank of Canada 78014RFV7 5 10,000,000 $ 10,000,000 Kt.._ ____ 39.4,Qp0 3.400 3.400 8/4/2022 8/4/2025 8/4/2025 Bullet 3.400 CD RBC $ 10,000,000 AA/AA- FHLB 3130APGQ2 $ 0,000,000 X $ 20,000,000 $ ^' 175,000 0.875 0.875 10/21/2021 10/21/2025 10/21/2022 * Qtly 0.875 FHLB $ 20,000,000 AA/AAA JP Morgan CD cusip 48128UQR3 $ 40,000,000 S 40,000,000 ll _._ 0.600 0.600 11/5/2020 11/5/2025 11/5/2022 Semi Annual 0.600 CD JPM S 40,000,000 AA/AAA __240,000 FHLB 3130AU39 $ 10,000,000 $ 9,242,760 t$_ 90,000 0.900 3.000 4/29/2022 a 3/3/2026 9/3/2022Qtly 0.900 FHLB S 9,242,76{; AA/AAA FHLB 3130ALHHO 5 10,000,000 $ 9,269,300 15 96,000 0.960 3.000 5/11/2022 3/5/2026 9/5/2022 Monthly 0.960 FHLB 9,269,300 AA/AAA FFCB 3133EMUK6 $ 5,000,000 $ 5,000,000 (_$. 52,500 1.050 1.050 3/25/2021 3/25/2026 9/21/2022 Continous 1.050 FFCB 5 5,000,00{) AA/AAA FFCB 3133EM3Y6 $ 20,000,000 $ 20,000,000 TS-_ , 186,000 0.930 0.930 9/3/2021 9/1/2026 9/21/2022 Continous 0.930 FFCB.,, S 20,000,000 AA/AAA FHLB 3130ANYN4 $ 10,000,000 $ 10,000,000 i_$. _ . 100,000 1.000 1.000 9/30/2021 9/30/2026 9/30/2022 Qtly 1.000 FHLB 5 10,000,000 AA/AAA FHLB 3130AQPR8 $ 10,000,000 5 10,000,000 B.-____-:,130,000 1.300 2.060 2/18/2022 2/18/2027 8/18/2022 Qtly 1.300 FHLB S 10,000,000 AA/AAA a Total / Wt'd Av Return $ 497,075,000 $ 485,049,816 $ 5,756,240 1.187% 1.266% $ 485,049,816 RESOLUTION RE APPROVE WELD COUNTY INVESTMENT POLICY AND AUTHORIZE CHAIR AND CHAIR PRO-TEM TO SIGN WHEREAS, the Board of County Commissioners of Weld County, Colorado, pursuant to Colorado statute and the Weld County Home Rule Charter, is vested with the authority of administering the affairs of Weld County, Colorado, and WHEREAS, the Board has been presented with an Investment Policy for the County of Weld, Colorado, State of Colorado, by and the through the Board of County Commissioners of Weld County, on behalf of the Treasurer's Office, with further terms and conditions being as stated in said investment policy, and WHEREAS, after review, the Board deems it advisable to approve said investment policy, a copy of which is attached hereto and incorporated herein by reference NOW, THEREFORE, BE IT RESOLVED by the Board of County Commissioners of Weld County, Colorado, that the Investment Policy for the County of Weld, State of Colorado, by and through the Board of County Commissioners of Weld County, on behalf of the Treasurer's Office, be, and hereby is, approved BE IT FURTHER RESOLVED by the Board that the Chair and Chair Pro-Tem be, and hereby are, authonzed to sign said investment policy The above and foregoing Resolution was, on motion duly made and seconded, adopted by the following vote on the 8th day of November, A D , 2021 BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO ATTEST dm) W ;4, Weld County Clerk to the Board BY71/f/14, eputy Clerk o the Board EXCUSED Stev- oreno, Chair S f" J=mes, Pr Perry L +' ck APP '.% ED A XCUSED County • orney Date of signature I VI 5ii-1 cc TR (RK/h), ACT(C°), FIDw/ce) 12/.3121 2021-3112 TR0030 WELD COUNTY INVESTMENT POLICY 2021 I. INTRODUCTION Section 64 of the Weld County Home Rule charter was amended by the Weld County voters on November 8, 2001, making the office of County Treasurer appointed by the Board of Weld County Commissioners, effective January 1, 2003. In order to fulfill their fiduciary responsibilities concerning the Treasurer's investments the Board of Weld County Commissioners decided that an oversight committee, known as the Investment Advisory Committee, should be created which includes the Treasurer, the Director of Finance and Administration, CFO, the Controller, the Chair, and Chair Protem of the Board of Weld County Commissioners. This Investment Policy replaces any previous Investment Policy or Investment Procedures of Weld County. The investment guidelines outlined below have been written to comply with various regulatory requirements under which Weld County operates. This Investment Policy was endorsed and recommended for adoption by the Weld County Investment Advisory Committee October 2021. II. SCOPE The following investment policy addresses the methods, and procedures to ensure effective and judicious fiscal and investment management of the County's funds. This policy shall apply to the investment management of all financial assets and funds under control of the County except for its employee retirement system fund, which is organized and administered separately by the Weld County Retirement Board. These investment transactions/activities are accounted for in the government's annual financial report and include the following: • General fund, • Special Revenue funds, • Debt Service funds. • Capital Projects funds, • Enterprise fund, • Internal Service funds, • Trust and Agency funds - Expendable Trust funds & Agency funds, and • Any new fund created by the governing body, unless specifically exempted by the governing body 2021-3112 III. INVESTMENT OBJECTIVES All funds which are held for future disbursement shall be deposited and invested by the County in accordance with Colorado State Statutes and ordinances and resolutions enacted by the Board of Weld County Commissioners in a manner to accomplish the following objectives: 1. Safety of Funds: Safety of principal is the foremost objective of the investment program. Investments shall be undertaken in a manner that seeks to ensure the preservation of capital in the overall portfolio. The objective will be to mitigate credit risk and interest rate risk. A. Credit Risk. The County will minimize credit risk, the risk of loss due to the failure of the security issuer, by: a. Limiting investments to the safest types of securities; b. Pre -qualifying the financial institutions, broker/dealers, and advisors with which the County does business, and c. Diversifying the investment portfolio so that potential losses on individual securities will be minimized. B. Interest Rate Risk: The County will minimize the risk that the market value of securities in the portfolio will fall due to changes in general interest rates by: a. Structuring the investment portfolio so that securities mature sufficiently close to cash requirements for ongoing operations, thereby minimizing the potential need to sell securities on the open market prior to maturity and b. Investing operating funds primarily in short- to intermediate -term securities, approved local government investment pools, approved money market mutual funds and repurchase agreements. 2. Liquidity of Funds: The investment portfolio shall remain sufficiently liquid to meet all operating requirements that may be reasonably anticipated. To ensure that adequate funds are available to pay the County's projected financial obligations, investments will be purchased that reasonably match the anticipated cash disbursements of the County. Since all possible cash demands cannot be anticipated, the portfolio shall consist largely of securities with active secondary or resale markets so that the potential for a realized loss, if an early liquidation of a security is necessary, can be minimized. A core of stable funds may be identified through cash flow analysis that is available for investing in longer -term securities. Although the market value of these longer term securities may fluctuate significantly, the fluctuation will not affect the liquidity of the portfolio since they can be held to maturity in all but extreme circumstances. 3. Yield: The County's portfolio shall earn a competitive market rate of return on available funds throughout budgetary and economic cycles. In meeting this objective, investment management personnel will take into account the County's investment risk constraints and cash flow needs. The County's overall investment program shall be designed and managed with a degree of professionalism that is worthy of the public trust. The County recognizes that no investment is totally free of risk and that the investment activities of the County are a matter of public record. Accordingly, the County recognizes that occasional measured losses are inevitable in a diversified portfolio and shall be considered within the context of the overall portfolio's return, provided that this policy has been followed and that the sale of a security prior to maturity is in the best long-term interest of the County. IV. DELEGATION OF AUTHORITY Authority to manage the investment program is granted to the Treasurer derived from Article 11 of the Weld County Home Rule Charter. Responsibility for the operation of the investment program is hereby delegated to the Treasurer, who shall cant' out established written procedures and internal controls for the operation of the investment program consistent with this investment policy. Procedures shall include references to: safekeeping, delivery vs. payment, investment accounting, repurchase agreements and banking services contracts. No person may engage in an investment transaction except as provided under the terms of this policy and the procedures established by the Treasurer. The Treasurer shall be responsible for all transactions undertaken and shall establish a system of controls to regulate the activities of subordinate officials. The Treasurer may engage the support services of outside professionals, so long as it can be demonstrated that these services produce a net fmancial advantage and necessary financial protection of the County's resources. Such services may include engagement of financial advisors in conjunction with debt issuance, portfolio management support, special legal representation, third party custodial services, and appraisal of independent rating services. V. PRUDENCE AND INDEMNIFICATION The standard of prudence, as defined by the Colorado Revised Statutes, to be used for managing the County's assets is the "prudent investor" rule applicable to a fiduciary, which states that a prudent investor "shall exercise the judgment and care, under circumstances then prevailing, which men of prudence, discretion, and intelligence exercise in the management of the property of another, not in regard to speculation but in regard to the permanent disposition of funds, considering the probable income as well as the probable safety of their capital" (CR5 15-1-304, Standard for Investments.) The Director of Finance, Treasurer and other authorized persons acting in accordance with written procedures and exercising due diligence shall be relieved of personal responsibility for an individual security's credit risk or market price changes provided deviations from expectations are reported in a timely fashion and the liquidity and the sale of securities are carried out in accordance with the terms of this policy. The Treasurer will be responsible for ensuring that sufficient liquidity exists to maintain the County's operations in the event of adverse market conditions or claims. VI. ETHICS AND CONFLICTS OF INTEREST As noted in Section 16-9 (2) (b) of the Weld County Home Rule Charter: "Neither the Treasurer nor employees of the Treasurer's Office shall have any proprietary interest in any financial institution in which the County maintains deposits." VII. ELIGIBLE INVESTMENTS AND TRANSACTIONS All investments will be made in accordance with the Colorado Revised Statutes (CRS) as follows CRS 11-10.5-101, et seq. Public Deposit Protection Act, CRS 11-47.101, et seq. Savings and Loan Association Public Deposit Protection Act; CRS 11-60-101, et seq. U.S. Agency Obligations; CRS 24-75-601, et seq. Funds -Legal Investments for Governmental Units; CRS 24-75-603, et seq. Depositories; and CRS 24-75-701, et seq. Local Governments -Local Government Pooling. Any revisions on extensions of these sections of the CRS will be assumed to be part of this policy immediately upon being enacted. This investment policy further restricts the investment of County funds to the following types of securities and transactions: A. Treasury Obligations: Treasury bills, Treasury notes, Treasury bonds and Treasury STRIPS with maturities not exceeding five years from the date of purchase. B. Federal Instrumentality Securities: Debentures, discount notes, global securities, callable securities and stripped principal on coupons with maturities not exceeding five (5) years from the date of purchase issued by the following only: Federal National Mortgage Association (FNMA), Federal Farm Credit Banks (FFCB), Federal Home Loan Banks (FHLB), Federal Home Loan Mortgage Corporation (FHLMC. For the purposes of this paragraph, a `weighted average life" will not constitute a stated final maturity. C. Repurchase Agreements with a defined termination date of 180 days or less collateralized by U. S. Treasury and agency securities listed in item 1 and 2 above with a maturity not exceeding 10 years. Title must transfer to the County of Weld or the County must have a perfected security interest. For the purpose of this section, the term "collateral' shall mean "purchased securities" under the terms of the County's approved Master Repurchase Agreement. The purchased securities shall have a fixed coupon rate and an original minimum market value including accrued interest of 102 percent of the dollar value of the transaction and the collateral maintenance level shall be 102 percent. Collateral shall be held in the County's custodial bank as safekeeping agent, and the market value of the collateral securities shall be marked -to -the -market daily based on that day's bid price. Repurchase Agreements shall be entered into only with dealers who have executed a Master Repurchase Agreement with the County and who are recognized as Primary Dealers with the Market Reports Division of the Federal Reserve Bank of New York. Approved counterparties to repurchase agreements shall have at least a short-term debt rating of A-1 or the equivalent and a long-term debt rating of A or the equivalent from one on more nationally recognized organizations which regularly rates such obligations. D. Local Government Investment Pools authorized under CRS 24-75-701, 702 which are managed to a stable value (usually $1 per share). E. Certificates of Deposit or savings accounts in state or national banks or in state or federally chartered savings and loans that are state approved depositories per CR5 24-75-603, et seq. (as evidenced by the State Banking Board) and are insured by the FDIC. Certificates of deposit which exceed the FDIC insured amount shall be collateralized in accordance with the Colorado Public Deposit Protection Act. [Allow CD purchases up to the FDIC limit in US banks outside of Colorado.] F. Negotiable Certificates of Deposit (CDs with a CUSIP number) must meet the same rating and maturity requirements for debt securities under item F below. G. Corporate or Municipal Debt that does not exceed five (5) years in maturity at the time of purchase with a AAA rating; or does not exceed three (3) years in maturity at the time of purchase if it is AA rated. H. Commercial Paper in accordance with Colorado State statutes in 24-75-603. I. Money Market Mutual Funds registered under the Investment Company Act of 1940 that meet Federal Securities Regulation 2A-7 standards. Any deviation from this list must be pm -approved by the Board of Weld County Commissioners in writing. VIH. INVESTMENT DIVERSIFICATION It is the intent of the County to diversify the investments in the portfolio to avoid incurring unreasonable risks inherent in over -investing in specific instruments, individual financial institutions or maturities. The asset allocation in the portfolio should, however, be flexible depending upon the outlook for the economy, the securities market, and the County's anticipated cash flow needs. A minimum of 50% of the investment assets of the County will be maintained in those securities listed in items A, B, C, D, and H under Eligible Investments and Transactions. IX. INVESTMENT MATURITY AND LIQUIDITY Investments shall be limited to maturities not exceeding five (5) years unless otherwise approved in writing by the Board of Weld County Commissioners for special circumstances (e.g., the reinvestment of bond proceeds). The County shall maintain at least 10% of its total investment portfolio in instruments maturing in 90 days or less. X. COMPETITIVE TRANSACTIONS Each investment transaction shall be competitively transacted with broker/dealers who have been authorized by the County. Securities shall be purchased at the then best offering price based on the market conditions at that time. XI. SELECTION OF BROICER/DEALERS AND FINANCIAL INSTITUTIONS ACTING AS BROKER/ DEALERS AND FINANCIAL INSTITUTIONS PROVIDING INVESTMENT SERVICES. The Treasurer shall maintain a list of authorized broker/dealers and financial institutions which are approved for investment purposes, and it shall be the policy of the County to purchase securities only from those authorized institutions and firms. To be eligible, a firm/investment bank, bank, or savings and loan institution must meet at least one of the following criteria: 1. Meet the securities dealer's capital adequacy requirements of the New York Federal Reserve Bank. The capital requirements are found in the New York Federal Reserve Bank publication entitled, Capital Adequacy Guidelines for Governmental Securities Dealers, or 4. Be an FDIC member and be listed as an "Eligible Public Depository" as prepared by the State Banking Board for banks and for Savings and Loans to be approved as an "Eligible Public Depository" by the Colorado division of Financial services. Broker/dealers and other financial institutions will be selected by the Treasurer on the basis of their expertise in public cash management and their ability to provide service to the County's account. Each investment firm authorized by the Treasurer shall be a FINRA reporting broker/dealer. Broker/Dealers shall also attest in writing that they have received a copy of this policy. A list of approved Broker/Dealers, Banks, and Savings & Loan institutions is included in various "Resolutions" performed by the Board of County Commissioners of Weld County, Colorado. XII. SELECTION OF BANKS AND SAVINGS AND LOANS (DESIGNATION UNDER CRS 11-10.5-106 (Banks) and CRS.11-47-105 (Savings & Loan)) AS DEPOSITORIES AND PROVIDERS OF GENERAL BANKING SERVICES AND ASSET POOLS AS DEPOSITORIES The Treasurer shall maintain a list of authorized banks, savings and loans, and public asset pools as depositories for Weld County funds which are approved by the Board of Weld County Commissioners by resolution per CRS 30-10-708 to provide depository and other banking services for the County. To be eligible for authorization, a bank is required to be designated an eligible public depository by the state banking board and a savings and loan must be designated an eligible public depository by the state commissioner of Banking. Additionally, banks or savings and loans, in the judgment of the Treasurer, who no longer offer adequate safety or service to the County, will be removed from the approved list. The list will be updated annually if any changes are requested to insure compliance. Depositories shall be selected based on ratings and competitive rates of return. XIII. SAFEKEEPING AND CUSTODY The Treasurer shall approve one or more financial institutions to provide safekeeping and custodial services for the County. A County approved Safekeeping Agreement shall be executed with each custodian bank prior to utilizing that bank's safekeeping services. To be eligible for designation as the County's safekeeping and custodian bank, a financial institution shall meet the following criteria: 1. Have a Bauer rating of 3 stars or better out of possible 5 -star rating or 2. Have a PMA Financial Network, Inc. overall rating of three minus or better on a scale of one to five with one being the highest quality for the most recent reporting quarter before the time of selection. Custodian banks will be selected on the basis of their safety and ability to provide service to the County's account with competitive pricing of their safekeeping related services. Custodian banks shall be selected through the County's procurement process, which shall include a formal request for proposal as needed. Custodial banks should be in the highest rating categories. SAFEKEEPING All purchased securities will be perfected in the name of the County. Sufficient evidence to title shall be consistent with modem investment, banking and commercial practices. All investment securities, except non-negotiable certificates of deposit and money market funds, purchased by the County will be held by a PDPA eligible Colorado State bank or delivered by either book entry or physical delivery and will be held in third -party safekeeping by a County approved custodian bank, its correspondent New York Bank or the Depository Trust Corporation (DTC). All non -book entry (physical delivery) securities shall be held by Weld County's designated custodian bank for the benefit of the county. The County may utilize the services of the Depository Trust Corporation (DTC) as a depository for delivery of non- wireable securities. All custodies securities that are registered shall be registered in the name of the County or in the name of a nominee of the County or in the name of the custodian or its nominee or, if in a clearing corporation, in the name of the clearing corporation or its nominee. The County's custodian will be required to furnish the County with monthly reports of holdings of custody securities as well as an account analysis report of monthly securities activity. XIV. PERFORMANCE BENCHMARKS The County of Weld shall use as a goal a dynamic benchmark rate of return or the current money market rate for the County's fixed income investment portfolio that corresponds to the yield for the current money market average return expressed as an annualized basis. All fees involved with managing the portfolio should be included in the computation of the portfolio's rate of return. The Treasurer shall present to the Investment Advisory Committee of Weld County a review of the current investments and the portfolio's adherence to appropriate risk levels and a comparison between the portfolio's total return and the established investment objectives and goals. XV. REPORTING Accounting and reporting on the County's investment portfolio shall conform to Generally Accepted Accounting Principles (GAAP) and the Governmental Accounting Standards XVII. POLICY REVISIONS This investment policy shall he reviewed as needed by the Director of Finance and Treasurer and may be amended by the Investment Advisory Committee of Weld County as conditions warrant. The data contained in the annexes to this policy may be updated by the Treasurer as necessary, provided the changes in no way affect the substance or intent of this policy. Exhibit I Authorized Personnel The following persons are authorized to transact investment business and wire funds for investment purposes on behalf of the Weld County: John Lefebvre, Treasurer Rene Fielder, Assistant Treasurer INVESTMENT COMMITTEE Lefebvr - reasurer Barb Connolly- C Gt,t/� Warden — Finance Director Steve Moreno - Board Chair Sc tt K. James, Pro-Tem November 2, 2021 Date 11 Date 11-4/4-/-1 De Da NOI/ 0 8 2021 Date O2 o„2 3""2_ Section 11-4 Investment of Funds. (1) The County Treasurer shall, with prudence, deposit available funds in accordance with the statutes of the State of Colorado giving preference to Weld County financial institutions (2) All interest from county funds shall become a part of the General fund, except that interest from particular funds may, by resolution of the Board, be retained in such fund Created 2022-08-02 18 29 35 [EST] (Supp No 78) Page 1 of 1 Weld County Investments (as of 9/14/22) Please note: Includes certain investments that will be managed internally (see RFP for more information) Weld County Assets Net of Fees 9/21/20?7 Call SP/Moody Rating Description Face Amt Cost Int Earned Rate YTM Settlement Mat Date Nxt Call Date Frequency Coupon Agency Amount 9/21/2022 CSIP CP Fund $ 20,000,000 $ 20,000,000 $ __ 328.600 1.640 1.640 5/27/2022 9/26/2022 9/26/2022 CP Bullet 1.640 CSIP CP . 20,000,000 Al CSIP CP Fund $ 10,000,000 $ 10,000,000 5 258,000 2.580 2.580 8/4/2022 10/4/2022 9/26/2022 CP Bullet 2.580 CSIP CP `: 10,000,000 Al FFCB 3133EMCU4 $ 10,000,000 S 10,000,000 S 19,000 0.190 0.190 7/12/2021 10/13/2022 9/21/2022 Continous 0.190 FFCB 5 10,000,000 AA/AAA CSIP CP Fund $ 5,000,000 $ 5,000,000 l_$ 79,000 1.580 1.580 3/25/2022 12/1/2022 12/1/2022 CP Bullet 1.580 CSIP CP $ 5,000,000 Al FHLB 3130AQK36 $ 5,000,000 $ 4,999,000 1$ 18,750 0.375 0.395 1/10/2022 1/10/2023 1/10/2023 Semi Annual 0.375 FHLB 5 4,999,000 AA/AAA Royal Bank of Canada 78014RCX6 $ ] 10,000,000 $ 10,000,000 J. 351,100 3.511 3.511 5/22/2020 5/22/2023 5/22/2023 Qtly Feb, May, Aug, 3.511 CD RBC + $ 10,000,000 AA2/AA- Bank of Montreal 06367WL84 $_ 10,000,000 $ 10,000,000 r 387,800 3.878 3.878 6/3/2020 6/3/2023 6/3/2023 Qtly Mar, Jun, Sep, 3.878 CD BM $ 10,000,000 AA2/AA- CSIP CP Fund t-71 10,000,000 $ 10,000,000$ 292,000 2.920 2.920 6/9/2022 6/9/2023 6/9/2023 CP Bullet 2.920 CSIP CP $ 10,000,000 Al FHLB 3130AN6V7 S 20,000,000 $ 20,000,000 ;$ 52,000 0.260 0.260 7/27/2021 10/27/2023 10/27/2022 Qtly 0.260 FHLB S 20,000,000 AA2/AA- Treasury 91282CAW1 S 25,060,000 $ 24,994,250 1.$ 62,500 0.250 0.260 8/27/2021 11/15/2023 11/15/2023 Bullet 0.250 UST :, 24,994,250 AA2/AA- FHLB 3130AMBUS $ 12,750,000 $ 12,750,000 is 47,813 0.375 0.375 5/17/2021 5/17/2024 8/17/2022 Qtly 0.375 FHLB $ 12,750,000 AA2/AA- FHLB 3130AQ3A9 5 20,000,000 S 20,000,000 [$. 200,000 1.000 1.000 12/21/2021 6/21/2024 9/21/2022 Qtly 1.000 FHLB S 20,000,000 AA2/AA- FHLB 3130ASZG7 $ 10,000,000 $ - & _„__ 4alQQQJ 4.000 4.000 9/16/2022 9/16/2024 12/16/2022 Qtly 4.000 FHLB $ AA2/AA- Palm Beach Co FL 696572MD5 5 5,325,000 $ 5,325,000 LS 26,625 0.500 0.500 10/27/2020 10/1/2024 10/1/2024 Bullet 0.500 Palm B S 5,325,000 AAA/AAA FHLB 3130ARKA8 $ 10,000,000 $ 10,000,000 KC__ 2$5,000 2.850 2.850 4/25/2022 10/25/2024 10/25/2022 Qtly 2.850 FHLB 5 10,000,000 AA/AAA FHLB 3130ANHG8 5 20,000,000 5 20,000,000 100,000 100,000 0.500 0.500 7/30/2021 10/29/2024 10/29/2022 Qtly 0.500 FHLB 5 20,000,000 AA/AAA US Treasury 912833LT5 Strips p S 10,000,000 $ 9,872,200 c$ 39,0.8 0.390 0.390 7/28/2021 11/15/2024 11/15/207.4 Bullet 0.390 USTS :7 9,872,200 AAA/AAA Flit MC 3134GXK86 $ 9,000,000 $ 9,000,000 360,000 4.000 4.000 8/18/2022 11/18/2024 11/18/2024 Qtly 4.000 USTS , 9,000,000 AAA/AAA FHLB 3130ANM49 $ _.j1,000,000 $ 20,000,000 Y_.l 80,000 0.400 0.400 8/24/2021 12/24/2024 10/1/2024 Bullet 0.400 FHLB 20,000,000 AAA/AAA FHLB 313ANLR9 $ 15,000,000 5 25,000,000 Ii 135,000 0.540 0.540 8/26/2021 12/26/2024 8/26/2022 Qtly 0.540 FHLB 5 25,000,000 AA/AAA FHLB 3130APAJ4 $ 25,000,000 $ 25,000,000 137,500 0.550 0.550 9/27/2021 12/27/2024 9/27/2022 Qtly 0.550 FHLB $ 25,000,000 AA/AAA FHLB 3130ANHH6 $ _j0,000,000 $ 20,000,000 a... - 112,000 0.560 0.560 7/30/2021 1/29/2025 10/29/2022 Qtly 0.560 FHLB S 20,000,000 AA/AAA USTN 912828ZT04 $ 30,000,000 $ 29,597,306 75,000 0.250 0.620 9/27/2021 5/31/2025 5/31/2025 Bullet 0.250 USTN S 29,597,306 IDC 293 FHLB 3130APL52 $ 10,000,000 $ 10,000,000 Ls 101,000 1.010 1.010 10/28/2021 7/28/2025 10/28/2022 Qtly 1.010 FHLB 5 10,000,000 AA/AAA FHLB 3130ASNU9 $ 10,000,000 $ 10,000,000 -$ 405,000.1 4.050 4.050 7/28/2022 1/28/2025 10/28/2022 Qtly 4.050 FHLB 5 10,000,000 AA/AAA Royal Bank of Canada 78014RFV7 $ 10,000,000 $ 10,000,000 f $ 340,0_00 3.400 3.400 8/4/2022 8/4/2025 8/4/2025 Bullet 3.400 CD RBC $ 10,000,000 AA/AA- FHLB 3130APGQ2 5 20,000,000 $ 20,000,000 '; _$ , 175,000 0.875 0.875 10/21/2021 10/21/2025 10/21/2022 Qtly 0.875 FHLB $ 20,000,000 AA/AAA JP Morgan CD cusip 48128UQR3 $ 40,000,000 $ 40,000,000 -_$_ _.240,000 0.600 0.600 11/5/2020 11/5/2025 11/5/2022 Semi Annual 0.600 CD JPM S 40,000,000 AA/AAA FHLB 3130AU39 $ 10,000,000 $ 9,242,760 _l 90,000 0.900 3.000 4/29/2022 3/3/2026 9/3/2022 Qtly 0.900 FHLB 9,242,760 AA/AAA FHLB 3130ALHHO $ . 10,000,000 $ 9,269,300 _ .1 96,000 ~ 0.960 3.000 5/11/2022 3/5/2026 9/5/2022 Monthly 0.960 FHLB 5 9,269,300 AA/AAA FFCB 3133EMUK6 - 5 5,000,000 $ 5,000,000;x' 52,500 1.050 1.050 3/25/2021 3/25/2026 9/21/2022 Continous 1.050 FFCB 5,000,000 AA/AAA FFCB 3133EM3Y6 5 20,000,000 S 20,000,000 nil .__ 186,000 0.930 0.930 9/3/2021 9/1/2026 9/21/2022 Continous 0.930 FFCB $ 20,000,000 AA/AAA FHLB 3130ANYN4 5 10,000,000 $ 10,000,000 $ _ 100,000 1.000 1.000 9/30/2021 9/30/2026 9/30/2022 Qtly 1.000 FHLB S 10,000,000 AA/AAA FHLB 3130AQPR8 - S 10,000,000 $ 10,000,000 i $ 130,000 1.300 2.060 2/18/2022 2/18/2027 8/18/2022 Qtly 1.300 FHLB $ 10,000,000 AA/AAA Total / Wt'd Ay Return $ 497,075,000 $ 485,049,816 $ 5,756,240 1.187% 1.266% $ 485,049,816 Investment Advisor Services B2200146 - Question & Answer Posted - October 5, 2022 1. Question 3.7 states "All performance numbers must be presented in accordance with the APT US&C." It is more common for public sector entities to report performance according to the Investment Performance Standards ("GIPS®"), the industry standard. Our firm reports performance composites according to GIPS®, which we believe to be in line with APT US&C's best practices as outlined in its Investment Policy Certification Program. Would reporting performance according to GIPS® be acceptable to the County? Answer: Yes, this would be acceptable. 1of1 Investment Advisor Services B2200146 — Questions & Answers #2 Posted — October 6, 2022 • Question 3.7 states "All performance numbers must be presented in accordance with the APT US&C." It is more common for public sector entities to report performance according to the Investment Performance Standards ("GIPS®"), the industry standard. Our firm reports performance composites according to GIPS®, which we believe to be in line with APT US&C's best practices as outlined in its Investment Policy Certification Program. Would reporting performance according to GIPS® be acceptable to the County? Yes, reporting performance according to GIPS would be acceptable. An old RFP template was used when preparing the RFP and we missed that update. Please do not worry about utilizing APT US&C Similar question regarding this topic included: o "All performance numbers must be presented in accordance with the APT US&C." Typically, investment advisors report performance according to the Global Investment Performance Standards (GIPS). We've read APT US&C's model investment policy regarding performance but are unsure of the specifics. Can you please elaborate regarding the specifics of APT US&C performance information format the County wants responders to utilize? • How is the County's portfolio currently benchmarked? The County does not currently benchmark its portfolio. The County currently does not benchmark its portfolio. Does the County have a preference for a specific benchmark? No preference, we will want our selected investment advisor to provide recommendations. We definitely will be benchmarking the portfolio in the future. Similar question regarding this topic included: o Does the county have a preferred benchmark? Does that mandate have a designated benchmark, or would you prefer managers propose one as part of our response? • The minimum service requirements include online reporting access. This is typically a function of the custodian, rather than investment manager - would the County be open to a combined investment management and custody offer? We currently use US Bank as our custodian and are not including custodial services in this RFP. If we were to change custodian, which we currently are not planning, we would do a separate RFP. • The minimum service requirements discuss non -discretionary or discretionary services, and then separately mention a requirement for initiating trades requiring permission from county staff prior to execution. Full discretion would not include execution permissions - is the County open to a fully discretionary mandate? We have not determined whether we would choose the fully discretionary option and will be deciding on that after we have chosen an investment advisor. • To demonstrate our capabilities, we would like to propose a portfolio based on our best thinking, which would include securities, such as lower investment grade credit securities or high -quality asset backed securities, that fall outside of the County's current investment policy statement (though they are allowable based on the Colorado State 1 Treasury's investment policy statement). Is the County open to proposals including securities that currently fall outside of the County's investment policy statement? We would be open as long as the investments are allowable. With the assistance of the investment advisor, we would recommend changes to the County's investment policy and bring to the Board of County Commissioners for approval. .• Is the County open to taking realized gains and/or losses in the portfolio via an actively managed approach that allows for more dynamic portfolio management, or does the County have a preference for a `buy -and -hold' approach (i.e., taking the approach of holding securities that are purchased within the portfolio to maturity)? We are open to taking realized gains and losses. • The County's investment policy statement requires that 10% of the overall portfolio be maintained in securities with maturities of 90 days or less. Can we assume that the shorter -term funds that will continue to be internally managed by the County will satisfy this requirement for the overall portfolio? Yes, short-term maturities will continue to be internally managed. • The County's investment policy statement requires that at least 50% of the overall portfolio be invested in Treasury Obligations, Federal Instrumentality Securities, Repurchase Agreements, Local Government Investment Pools, and Commercial Paper. Can we assume that the shorter -term funds that will continue to be internally managed by the County will be 100% invested in those securities (allowing more flexibility for the externally managed portion of the portfolio)? Yes, shorter -term funds will continue to be managed internally. • Will you provide the name of the current Investment Advisor? Does the County have an existing external manager for this mandate? We currently do not have an external investment advisor. All investing has been performed by internal staff. • Will you provide the current fee for this mandate? N/A. This work is done in-house. We are not providing the expected budget for these services. • Does the county have an average life or duration limit? Per the County's investment policy, investments shall be limit to maturities not exceeding 5 years unless otherwise approved, in writing, by the Board of County Commissioners for special circumstances (e.g., reinvestment of bond proceeds). • Does the County have an existing custodian for its assets? If yes, can you advise who the current custodian is? Yes, US Bank is the County's custodian. • Does the County anticipate a security in kind funding of the mandate, or a cash funding? The County will have the selected investment manager take over our management of our existing portfolio. • Does the file size limit and page limit include standard attachments, such as an ADV or sample client report, or does this limit only apply to the response to the questionnaire? The page limit only applies to responses in the questionnaire, not to 2 standard attachments. Feel free to add the documents you discussed either as links or attachments. Email proposals to bidsgweldgov.com; however, if your proposal exceeds 25MB please upload it to https://www.bidnetdirect.com. The maximum file size to upload to BidNet Direct is 500 MB. Similar questions regarding this topic included: o On page 11 of the RFP, Section 1.7 states, "Provide a copy of your firm's most recent annual audited financial statements." Our corporate annual report is over 200 pages long. With the 75 -page limit, would it be acceptable to provide a link to the report in lieu of a copy? o On page 11 of the RFP, it states, "Please limit responses to no more than 75 pages." On page 12 of the RFP, Section 2.7 asks responses to provide copies of our conflict of interest and code of conduct policies. The document containing these policies is 6 pages long. Does the 75 -page limit exclude the requested policies, and can they be placed in the Exhibits o On page 11 of the RFP, it states, "Please limit responses to no more than 75 pages." On page 13 of the RFP, Section 4.5 asks responses to include sample reports. Our sample reports (and other investment advisor's reports) are generally 50-75 pages, when including monthly investment reports, economic reports, etc. Does the 75 -page limit exclude the requested sample reports? o For the 75 -page limit, can you please let us know if that includes appendix items and/or attachments? If so, please specify which attachment/appendix items that are requested throughout the questionnaire would be counted? Exhibit B Christie Peters From: Sent: To: Subject: Attachments: Proposals <proposals@chandlerasset.com> Wednesday, October 19, 2022 9:13 AM bids INVESTMENT ADVISOR SERVICES RFP Investment Advisor Services RFP_Chandler.pdf Caution: This email originated from outside of Weld County Government. Do not click links or open attachments unless you recognize the sender and know the content is safe. Hello, Thank you for the opportunity to present our qualifications to provide investment advisor services for the County of Weld. On behalf of Chandler Asset Management, Inc., I am submitting our bookmarked proposal and referenced appendices for consideration by the County's Finance Staff. I hereby waive my right to a sealed proposal. Please do not hesitate to contact Scott Prickett, Co -Chief Investment Officer, directly at (720) 308-6102 or via email at sprickett@chandlerasset.com. with any questions or concerns regarding our submission. We look forward to discussing our qualifications in greater detail and thank you once again for your consideration. Best, Heather Wolfe Content Manager Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 800.317.4747 hwolfe d chandlerasset.com www.chandlerasset.com at CHANDLER ASSET MANAGEMENT The information contained in this e-mail message, including any attached files transmitted, is confidential and may be legally privileged. It is intended only for the sole use of the individual(s) named above. If you are the intended recipient, be aware that your use of any confidential or personal information may be restricted by state and federal privacy laws. If you, the reader of this message, are not the intended recipient, you are hereby notified that you should not further disseminate, distribute or forward this e-mail message. If you have received this e-mail in error, please notify the sender and delete the material from your computer system. This message is provided for information purposes and should not be construed as a solicitation or offer to buy or sell any securities or related financial instruments in any jurisdiction. 1 Ktrarm‘a rig, Request for Proposals for: Weld County ill or, • INVESTMENT ADVISOR SERVICES I DUE: October 19, 2022, 10:00 AM r 1875 Lawrence Street, Suite 920 Denver, Colorado 80202 Direct: 720-907-0829/ Toll free: 800-317-4747 info@chandlerasset.com I chandlerasset.com iorPo CAN CHANDLER ASSET MANAGEMENT October 18, 2022 Weld County, Colorado 1150 O Street Greeley, CO 80631 RE: Request for Proposals - Professional Investment Advisor Services for Weld County Dear Ms. Patteli and Board of County Commissioners of Weld County, On behalf of Chandler Asset Management, Inc. ("Chandler"), we are pleased to submit our firm's proposal and present our qualifications to provide discretionary investment advisory services for Weld County ("the County"). Chandler is an SEC -registered investment adviser founded on the tenets of public agency investing and guided by the objectives of our clients for safety of principal, access to liquidity, and yield/return over a market cycle. Our firm has provided comprehensive investment solutions for local governments across the nation for over thirty years. Founded in 1988 by investment officers for public agencies, we provide access to advice and investment manager analysis while bringing clients a personalized and local perspective. As of June 30, 2022, Chandler manages $26.8 billion in firm -wide assets. The County will benefit from frequent and direct contact with investment team members that are committed to exceeding your expectations for investment advice for your funds as a fiduciary as well as for client service during the engagement. We will be proactive in our communication with you and your staff and will attend regular meetings with the County's finance and accounting staff and Board of Directors. We have reviewed the minimum requirements and scope of services in the RFP, and intend to add value to the investment program through the strategies summarized below, and explained in greater detail in our proposal: Act as a discretionary investment adviser and communicate effectively as to appropriate asset classes, purchases, and sales prior to any transactional activity in the County's portfolios. Meet in - person regularly and provide complete transparency of the entire investment program to the County's finance staff and Board of Directors. Develop a comprehensive investment policy that complies with Colorado Revised Statutes and the Master Bond Resolution, encompasses the latest industry best practices, and meets your priorities for ensuring safety and liquidity while optimizing investment return. Annually, work with your staff to review the investment policy and incorporate any changes to your objectives, risk tolerances, or cash flow requirements. Develop a comprehensive investment strategy that supports the County's financial goals, current budgetary objectives, and long-term general plan. The strategies will seek to increase interest income as well as protect and enhance portfolio market value by actively diversifying sectors, issuers, and maturities in each of the County's specially purposed portfolios. Our commitment to providing personalized client service is equal to our commitment to meeting investment objectives, and is reflected in the following: 1875 Lawrence St., Ste. 920 I Denver, CO 80202 I Phone 800.317.4747 I chandlerasset.com CHANDLER ASSET MANAGEMENT We understand your investment perspective. Chandler was founded by investment officers of large public agencies and is based on the same investment management principles that guide these entities today. Chandler's significant expertise in safeguarding our clients' funds while generating compelling risk -adjusted returns over many market cycles highly qualifies us to meet the needs of this engagement. We are experts in Colorado public agency investing. Chandler's investment professionals are experts in applicable federal laws and Colorado Revised Statutes regarding qualified investments for public funds. The County's assigned key investment contacts, Julie Hughes and Scott Prickett, CTP have decades of public sector investment experience and are active in organizations relevant to public fund investment best practices, including the Government Finance Officers Association (GFOA), the CFA Institute, and the Association of Public Treasurers of the United States and Canada (APT). Our staff members are highly regarded industry experts and frequent participants, speakers, and sponsors at industry conferences in Colorado as well as at events nationwide. We are committed to client success. We are dedicated to our role as fiduciaries to our clients and understand the public role that your investment staff has in the stewardship of taxpayer funds. The firm invests in best - in -class technology and resources that assist our investment professionals to develop both long-term and short-term strategies that are significant to the overall financial program. Our reports provide transparency of the entire investment program, and we commit the full resources of the firm to ensure your success. We are immensely proud of our client retention record, which we attribute to our belief that "if we do what is right for our clients, our own success will follow." As the firm's President, I am legally authorized to bind the firm. I certify that all the information provided in our proposal is accurate, firm, and irrevocable, and shall be valid for a period of at least ninety (90) days from October 19, 2022. We confirm that we have read the County's Request for Proposal in its entirety and will comply with all stated terms and conditions. We welcome the opportunity to speak with you in person about the County's goals and objectives. If you have any questions, please contact Scott Prickett, Co -Chief Investment Officer, directly at (720) 308-6102 or via email at sprickett@chandlerasset.com. Sincerely, CHANDLER ASSET MANAGEMENT, INC. Nicole Dragoo, JD, IACCP President 1875 Lawrence St., Ste. 920 I Denver, CO 80202 I Phone 800.317.4747 I chandlerasset.com CAt CHANDLER ASSET MANAGEMENT Request for Proposals (92200146) for Investment Advisor Services WELD COUNTY, COLORADO TABLE OF CONTENTS 1. ORGANIZATION 1 2. PERSONNEL 9 3. INVESTMENT MANAGEMENT APPROACH 16 4. REPORTING 27 5. FEES 33 6. REFERENCES 35 7. OTHER CONSIDERATIONS 36 REQUIRED FORMS Signature Form W-9 CHANDLER APPENDICES Form ADV, Parts 1 and 2 Appendix A Professional Biographies Appendix B ACORD Certificate of Liability Insurance Appendix C Global Investment Performance Standards (GIPS®) and Verification Letter Appendix D Important Disclosures Appendix E Sample Client Monthly Account Statement, Quarterly Investment Report and Appendix F GASB 40 and 72 Reports Proposed Additional Terms Appendix G Organizational Chart Appendix H Financial Statements (Confidential) Appendix I Quarterly Returns Report Appendix I CM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO 1. ORGANIZATION 1.1 Describe the organization, date founded, number of employees, location of your firm's offices, and ownership of your firm as well as any subsidiaries and affiliates relevant to the county. Firm Description Chandler Asset Management Inc.'s ("Chandler") core expertise is providing fully customized, high -quality fixed -income investment solutions for public agency clients. We are experts in managing public funds, providing excellent stewardship over the investment activities entrusted to us, and have, for over three decades, performed our fiduciary duty with discipline and care. Our firm provides comprehensive investment solutions for local governments that are guided by the objectives of preservation of principal, access to liquid funds, and maximization of investment returns within established risk parameters and legal requirements. From our over three decades of experience and client -focused approach, we understand firsthand the challenges of investing public funds in a world with dynamic financial markets and economic conditions. History Chandler was founded in 1988 by Kay Chandler as a result of her experience serving as an Investment Officer for the County of San Diego for eight years, and for the City of San Diego for another two years. With many responsibilities for treasury management and finance functions within these departments, Ms. Chandler recognized that public entities with limited time and resources could benefit from external professional expertise and technological resources to help manage their investment programs. In 1991, Martin Cassell, Ms. Chandler's successor on the investment staff of the City of San Diego, joined the firm. Mr. Cassell now serves as Chandler's CEO. Over the years, Ms. Chandler and Mr. Cassell carefully assembled a team of professionals with the specialized professional expertise and technical skills necessary to structure highly effective, fixed -income cash and core investment programs for cities, counties, and other local government entities. The firm manages $26.8 billion as of June 30, 2022, including $22.5 billion in separately managed accounts for 183 public agencies. All of the firm's Portfolio Managers are CFA charter holders, or currently pursuing the charter, and are committed to strengthening and sharing their knowledge of prudent standards of investment management for public funds. The comprehensive services we offer including portfolio management, regulatory guidance, and increased transparency through comprehensive reporting are designed to meet the specific needs of public agencies. Chandler remains committed to our conservative fixed -income management principles as the firm continues to evolve in response to our clients' needs and to the public investment climate. As a result of our significant growth and in support of our objectives, we serve our clients from six other offices besides our San Diego headquarters, located in Denver, Colorado; Orlando, Florida; Ventura, California; Oakland, California; Marin County, California; and Seattle, Washington. The firm's professional staff currently totals 42 individuals and includes 15 investment team members. Provided below are the total assets under management over the past 21 years in 5 -year increments. This demonstrates the continued growth that results from our values and culture centered around client success. Chandler's Mission and Core Values delineated below are what guide our client -focused approach to investment advisory services. 1) Page GM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO $30 $25 $20 $15 $10 $5 $- Chandler's Total AUM ($ billions) 2001-2022 $25.7 $2.8 $1 $5.8 ■ $11.7 $26.8 2001 2006 2011 2016 2021 2022 Chandler's institutional assets under management for the past twenty years and the current year (12/31/2001- 6/30/2022). Includes both discretionary and non -discretionary assets. Advised assets are excluded. Firm Structure and Ownership Chandler is an independent and 100% employee -owned corporation. In 2017, Chandler's key shareholders and Executive Management Team introduced an Employee Stock Ownership Plan ("ESOP") that aligns with the firm's values and culture of shared success. Every employee is an owner through the ESOP Trust, which owns 68% of the firm and is the primary shareholder. We believe that this structure contributes to our ability to attract and retain the highest quality investment professionals as well as to sustain growth, promote accountability, and best serve current and prospective clients well into the future. 1.2 Describe your firm's core mission, vision, and values. Chandler's Mission Our Mission Statement affirms our dedication to "earn the trust of every client, every day", and aligns with our Vision: "To be the preferred and most trustworthy investment advisor. We bring the highest value, share knowledge, and provide dedicated service to our clients, employees, and community." We understand the significance of being honest, open, and consistent to serve the best interest of our clients. We believe that by acting as a fiduciary and helping the County in accomplishing its own goals of cultivating partnerships to promote public health and environmental quality through the delivery of relevant, innovative, and cost-effective services, we too will accomplish ours. Chandler Asset Management: Credo: "We believe if we do what is right for our clients, our own success will follow." 21 Page CM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Chandler Asset Management — Core Values Essential to fulfilling our mission are our Core Values, which come from the high standards and vision of the individuals who built the firm, and are shared by all our employees: Integrity: We hold ourselves to the highest standards of ethics, always putting the interests of our clients before our own. Relationships: We value building strong relationships with our clients and with one another through cooperation and mutual respect. Service: We strive to provide superior service, quality, and value to our clients and our communities. Excellence: We are committed to exceeding our clients' expectations in all that we do. Education: We encourage and support the continuing education of our staff and are committed to thought leadership with our clients and within our industry. Our Fundamentals Program In 2018, Chandler created a corporate cultural program to express goals, through values and beliefs. Our 27 Fundamentals guide our activity and provide clarity on Chandler's firm culture. Chandler's singular focus since 1988 has been to provide investment strategies to public agencies, institutions, and other risk - conscious clients through the management of high -quality fixed -income portfolios. Our clients benefit from our disciplined, repeatable process and exceptional standard of care. We believe our process and attention to clients are rooted in our distinctive company culture. Chandler's unique culture is best captured in the 27 Fundamentals (shown below) that serve as a road map in our business and behaviors. These are the principles that guide all of our internal processes and direct our relationships. Chandler has created firm activities to reinforce and champion our Fundamentals on a weekly basis. Do the right thing, always INVEST IN RELATIONSHIPS GET CLEAR ON BE A FIDUCIARY Be relentless about improvement EXPECTATIONS Walk in your clients ' shoes PRACTICE BLAME FREE PROBLEM SOLVING BE PROCESS -DRIVEN 2 r Listen Generously CELEBRATE Communicate to be understood 3 KEEP THINGS FUN SUCCESS TREASURE, PROTECT AND Be a fanatic about response time o �, PROMOTE OUR REPUTATION LOOK AHEAD AND ANTICIPATE BE EASY TO WORK WITH QUALITY MAKEPERSONAL SPEAK STRAIGHT Go the extra mile O .n OHonor Commitments Make healthy choices "Bring it" Be curious THINKTEAM FIRST WORK ON YOURSELF every day. Chandler remains committed to our principles of conservative fixed income management as the firm continues to evolve in response to our clients' needs and to the public investment climate. As a result of our culture, mission statement, and core values, Chandler continues to grow and offer best -in -class investment strategies for water districts and other public agencies nationwide. 3IPage CM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Diversity, Equity, Inclusion, and Belonging History at Chandler We recognize that our employees comprise a wide range of backgrounds and characteristics, and we believe those differences should be celebrated and valued. Whether its race, religion, gender, national origin, ancestry, color, language, age, marital status, sexual orientation, gender identity, gender expression, physical or mental disability, medical condition, genetic information/characteristics, veteran status, political affiliation or any other characteristic, these are parts of each person that contribute to the experiences as humans and ultimately to the knowledge and expertise that makes our employees a valuable asset to Chandler. Chandler has a deep history of incorporating Diversity, Equity, Inclusion, and Belonging ("DEIB") through the fabric of the firm. Chandler was founded by a woman in 1988. Our current President is a woman. Our current workforce is 45% female. Chandler is committed to fostering a diverse workforce and maintaining an equitable, inclusive, and safe workplace for all employees. From recruiting practices to pay and benefits, promotions, and all other employment aspects, an environment of equity is of the utmost importance. Chandler is committed and determined to provide access, opportunity, and advancement for all individuals. We are always looking for ways in which we can cultivate an inclusive work environment, strengthen our cultural competency, and train our managers and employees to provide opportunities for growth and development. It is our intention that all our employees, regardless of any particular background or characteristic, are always treated with respect and dignity. We expect our employees, to treat their coworkers, supervisors, and other team members with the same dignity and respect at all times. In 2017, Chandler's key shareholders and Executive Management Team introduced an Employee Stock Ownership Plan ("ESOP") that aligns with the firm's values and culture of shared success. Every employee is an owner through the ESOP Trust, which owns 68% of the firm and is the primary shareholder. We believe that this structure contributes to our ability to attract and retain the highest quality investment professionals as well as to sustain growth, promote accountability, and best serve current and prospective clients well into the future. At the core of our DEIB efforts is our commitment to a distinctive corporate culture, evidenced by our Fundamentals. Code of Ethics Chandler Asset Management places the highest priority on maintaining its reputation for integrity and professionalism. That reputation is a vital business asset. The confidence and trust placed in Chandler and its employees by its clients is something we value and endeavor to protect. The firm's CCO provides New Employee training on each new employee's first day of employment. This training covers the main areas of focus contained within our firm's required Annual Compliance Training. All Chandler employees receive annual compliance training annually in March. Annual Compliance training focuses contains the following subjects: • Code of Ethics • Personal Securities Trading • Gifts & Entertainment • Political Contributions • Outside Business Activities • Conflicts of Interest 4IPage Cit CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO • Insider Trading / Material Non -Public Information • Privacy • Cybersecurity • Social Media Annually during the third quarter, Chandler utilizes a third -party vendor (NRS Compliance Guardian) online training platform for its required anti -money laundering training. The firm's CCO also provides ad hoc training throughout the year on key compliance and risk issues and industry hot topics. This training is provided during our weekly firm -wide staff meetings. 1.3 Identify the types of accounts primarily sought by your firm. Chandler's focus is on the management of high -quality fixed -income securities in strategies that span the yield curve for public entities and other risk -conscious institutions. Our clients share common objectives for their investment programs that prioritize the safety of principal, appropriate liquidity, and risk - adjusted total return over a market cycle and comply with federal laws and state legal requirements. All of Chandler's public agency clients' funds are structured as separately managed accounts. We customize portfolios to comply with individual clients' investment directives for operating funds, debt service, capital improvement, and any other funds that may have specific constraints. Our clients include cities, counties, water and wastewater districts, transportation authorities, school districts, higher education, healthcare districts, insurance funds, foundations/endowments, not -for-profit organizations, and corporations. We provide complete investment services and treasury management support for a public entity investment program, including: Investment Management Post -Employment Benefit Trusts/OPEB General Revenue Funds I Portfolio Review Bond Proceeds f Investment Policy Development and Review Capital Project Funds 1 Portfolio Accounting Debt Service Funds j Compliance Monitoring and Reporting Reserve Funds Fixed Income Education and Training 1.4 Describe the experience of the firm in serving as investment advisor for counties and other public entities. Please cite specific instances of portfolios managed and include dollar volume in the portfolio. Identify the individuals from the firm who had principal responsibility for the account. Chandler manages over $2.3 billion in assets for twenty-six Colorado institutional clients including the following: List of Colorado Public Agency Clients CLIENT NAME AUM CLIENT NAME AUM TOWN OF BRECKENRIDGE BROADWAY STATION METROPOLITAN DISTRICT 2 & 3 $28 M CITY OF LAKEWOOD $39 M CITY OF LOUISVILLE 5 $59 M $51 M CAt CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO CEMETERY ENDOWMENT FUND FOR COLORADO SPRINGS COLORADO SPRINGS UTILITIES OF CE TEN CITY & COUNTY OF DENVER DENVER HOUSING AUTHORITY DOUGLAS COUNTY E-470 PUBLIC HIGHWAY AUTHORITY EAGLE RIVER WATER & SANITATION DISTRICT TOWN OF ERIE CITY OF FEDERAL HEIGHTS $12 M $153 M $43 M $399 M $38 M $342 M $387 M $31 M $58 M $20 M TOWN OF PARKER PITKIN COUNTY PLAZA METROPOLITAN DISTRICT ROUTT COUNTY TOWN OF SILVERTHORNE SOUTH METRO FIRE RESCUE TRI-COUNTY HEALTH DEPARTMENT UNIVERSITY OF DENVER CITY OF WESTMINSTER WIDEFIELD SCHOOL DISTRICT $21 M WOMAN CREEK RESERVOIR CITY OF GREENWOOD VILLAGE AUTHORITY $56 M $71 M $7 M $57 M $17 M $8 M $6 M $17M $304 M $9 M $10 M As of 06/30/2022. A sample listing of the firm's Colorado public agency clients shown in alphabetical order. This list includes only clients that have given permission to be listed. Includes discretionary and non -discretionary relationships. It is not known whether the listed clients approve or disapprove of Chandler Asset Management or the services provided. 1.5 Does your firm act as a broker or primary securities dealer? Other than direct fees paid by clients, does your firm receive any other form of additional compensation (including soft dollars) for client transactions? Chandler does not act as a broker or dealer in securities or receive any other form of additional compensation. The firm's revenue is derived entirely from fees for investment management and advisory services received from our clients. As of our most recent fiscal year-end, approximately 90% of the firm's revenue is from institutional accounts. As an independent firm, Chandler maintains no other business affiliations, thereby avoiding any potential conflicts of interest that could interfere with our ability to provide independent and unbiased advice to our clients. This structure best serves our clients, as there are no conflicts or competing demands on best execution or upselling of services. 1.6 Please describe the financial condition of your firm, parent, or affiliate. Within the past five years, have there been any changes in ownership or restructuring? If anticipated, describe any future, significant changes to your firm. In 2022, William Dennehy II, CFA, Scott Prickett, CTP, and Jayson Schmitt, CFA were promoted to Co -Chief Investment Officers. Martin Cassell, CFA, CEO transitioned all CIO responsibilities to the three new CO- CIOs as of January 1, 2022. Nicole Dragoo, Chandler's COO and Chief Compliance Officer was promoted to President in April 2021. Joseph Kolinsky, hired as Compliance Manager in January 2020 now serves as Chief Compliance Officer. Other additions to our staff include Ryan Tauber, MBA, Managing Director of 6IPage CAS CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Business Development, who, since 2020, oversees the firm's sales, marketing, and client service efforts. Chandler continues to create new positions to accommodate growing business demands. 1.7 Provide a copy of your firm's most recent audited financial statements. We provided a copy of our most recent audited Financial Statements in the Appendix. We request that the County maintain the confidentiality of these documents as Chandler is a privately held firm. 1.8 Discuss your firm's assessment of the current market outlook and how your firm plans to provide superior performance for clients in the years ahead. Market volatility has intensified as financial conditions tighten and global central banks pursue monetary policies to combat persistently high inflation and maintain financial market stability. Labor markets and consumer balance sheets remain strong; however, inflation is weighing heavily on consumer sentiment and beginning to impact discretionary spending. Corporate earnings have generally performed better than expected, but warnings are growing along with wider credit spreads. While evidence of slower economic conditions has begun to mount, we expect the Federal Reserve to continue to raise rates until a sustainable improvement in inflationary conditions has been achieved. Over the near -term, we expect financial market volatility to remain intensified and conditions tighter with persistent inflation, geopolitical risk, and the Fed's hawkish monetary policy. Our strategies are designed to work over the long run over multiple interest rate cycles, as we do not time the markets. Despite this, we would be cautious in building out the County's investment strategy, tactically positioning the portfolio to have ample liquidity to take advantage of rising rates. We advocate having a diversified portfolio that allows for allocations to all fixed income investments permitted by the investment policy meeting the tenets of safety, liquidity, and return. We believe the best way to provide superior performance over the long -run is to maintain discipline with the investment strategy that best suits the County's risk tolerance. As financial conditions and financial markets change as they have over the past twelve months, we adapt our portfolio strategy to reflect the opportunities available in the market to meet our clients' return objectives. Our clients' portfolios are structured for long-term performance, and our processes are designed to filter the market noise and search for opportunities that will achieve the long-term goals of our clients. Chandler provides regular updates to keep you fully informed of investment strategies, market conditions, and developments that are relevant to your investment program. We encourage ongoing discussions as needed to ensure that the investment strategy remains consistent with the understood goals and objectives. We are pleased to provide ad -hoc economic presentations in addition to our regular quarterly report updates. Additionally, we communicate regularly via email to our clients with updates which include: Weekly economic updates provide a concise summary of economic and market news of the current week, key economic indicators, as well as topics for the next weeks' economic data releases. The update is sent via an email service that clients and interested parties receive each Friday; Monthly newsletter that includes a market summary, treasury yield curve graph and monthly percent changes, as well as economic data and statistics; and Ad hoc emails and communication such as Fed rate news, education pieces, whitepapers, technology and product updates. We have enclosed our latest Weekly Economic Review and monthly newsletter in the Appendix. These economic and market updates provide the most recent assessment of Chandler current market outlook. 7IPage CHANDLER ASSET MANAGEMENT WELD COUNTY, COLORADO Request for Proposals (82200146) for Investment Advisor Services 19 Describe why accounts/clients, if any, have dropped the firm in the past five years Chandler has lost only eighteen (18) clients and gained eighty-two (82) clients since June 30, 2017 Institutional accounts have closed because they needed liquidity or spent down bond proceeds 1 10 Within the past ten years, has your organization or an officer or principal been involved with any business litigation, SEC, or regulatory censure, or other legal proceedings related to your consulting activities? Please provide details with respect to the current status or disposition Neither Chandler nor any of its officers or employees has ever been subject to any regulatory censure or litigation by the SEC, NASD, or other regulatory agencies in relation to the investment management and advisory services it provides 1.11 Please disclose any potential conflicts of interest There are no known conflicts of interest that would prohibit Chandler from entering into an agreement with the County to provide investment management services or would otherwise adversely affect the County, its operations, or its customers As an adviser and fiduciary to our clients, their interests must always be placed first and foremost A foundation of our compliance program is conducting periodic risk assessments to identify potential conflicts or other areas of risk that we will then seek to disclose, and/or mitigate or eliminate within our policies and procedures Additionally, every Chandler employee is required to complete a Conflicts of Interests Questionnaire annually, or more frequently as changes necessitate which requires employees to disclose outside business activities, personal brokerage accounts and related transactions, political contributions, gifts and entertainment, criminal or civil litigation or convictions, relationships with vendors, brokers, or custodians and any other activities that could be an actual or potential conflict of interest The firm's compliance team reviews all questionnaires and will require additional disclosure, where necessary Furthermore, we commit to disclosing future actual or potential conflicts of interest and will refer to our Compliance manual to identify the best practice for resolving any such conflicts 8 (Page CA%icHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO 2. PERSONNEL 2.1 Identify the size of the firm's staff commitment to the public sector. Chandler Asset Management has a professional staff of forty-two (42) professionals dedicated to advising public sector clients regarding investment management, who are categorized as follows: Chandler Asset Management Professional Staff Classification # of Professionals CEO 1 President 1 Chief Investment Officers 3 Investment Management and Research 11 Client Service & Marketing 13 Operations 7 Compliance 3 Administration/Human Resources 3 Chandler professional staff as of 09/30/2022 2.2 Provide an organization chart showing your proposed project team to provide the services required in this RFP, including analytical investment and research staff, and back -office support. Please identify the primary contact and describe the role of the primary contact and of each key person on the team. How do you provide backup if the primary contact person is unavailable? Organization Chart. Provided below is an organizational chart of the primary team assigned to the County: Ben Mendenhall Sr. Relationship Manager Martin Cassell, CFA CEO if Jayson Schmitt, CFA Co -CIO r - Nicole Dragoo, JD, IACCP'N President Scott Prickett, CTP Co -CIO Julie Hughes Sr. Portfolio Strategist Stacey Alderson, CTP Client Service Director 9IPage co CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO For detailed organization chart of all team members, please see the Organizational Chart in the Appendix. 2.3 Provide summary biographies and/or resumes of individuals who would be providing investment advisory services to the county, including professional designations and/or licenses. For each individual describe their proposed role (including proposed time commitment) and list their relevant experience and substantive areas of expertise. Chandler believes in a customized approach with direct, in -person access to the professionals responsible for the investment program. The County will have frequent, direct face-to-face, phone, and email interactions with the portfolio strategists in addition to the rest of the Investment Management team. Our investment professionals work closely with our client service, operations, and compliance professionals to ensure you receive world -class service in all aspects of the relationship, not limited to investment management. The key professionals are listed in the following table: Chandler Asset Management Professionals for 2022 Contact Name and Title Role in Engagement Industry Tenure Firm Tenure Education Investment Management • • Julie Hughes, CTP • Senior Portfolio f Senior Portfolio Strategist Implements portfolio strategies Monitors alignment with client objectives and policies 29 years 8 years B.B.A. Marketing, University of Texas, Austin; M.B.A, The Wharton School, Strategist • Research and analysis University of • Builds & maintains client relationships Pennsylvania B.A. Business • Scott Prickett, CTP • Co -Chief Investment Officer Implements portfolio Administration, University of Northern Co -Chief Investment 35 years 8 years Officer • strategies Research and Analysis Colorado, Certified Treasury Professional (CTP.) • Co -Chief Investment Officer • Co -leads the investment team • Implements portfolio strategies • Research and Analysis B.A. Economics, San Jayson Schmitt, CFA • Co -Chief Investment Co -Chair of Quantitative Analysis Committee and 28 years 27 years Diego State University, Chartered Financial Officer Multi -Asset Class Committees Analyst (CFA.) 10 IPage GM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Engagement Management & Client Service • Relationship Manager & Key Contact Ben Mendenhall • Conducts onboarding process B.S. Business Senior Relationship • Manager Oversees client 16 years <1 year Management & Finance, University of Rhode communication Island • Ensures and coordinates project deliverables • Stacey Alderson, • CTP Client Service Contact Reporting requirements and B.B.A. Accounting, University of Client Service Client Portal 24 years 8 years Montevallo, Certified Director • Schedules training and educational presentations Treasury Professional (CTP®) Compliance & Oversight • Martin D. Cassell, • CO CEO • Chief Executive Officer Leads the firm's vision, oversight, and strategy CFA' designation 35 years 31 years B.S. Finance, California State University, Hayward, CFA® charter holder • Head of Firm Administration, Compliance, Operations, and B.A. Business Human Resources Economics, J.D. Nicole Dragoo, JD, • Responsible for regulatory University of San IACCP compliance and legal matters 22 years 21 years Diego; Investment Adviser Certified President • Directly manages investment operations Compliance Professional (IACCP) • Oversees firm's administrative functions designation • Leads Firm Compliance • Joseph Kolinsl y Oversees firm's compliance Chief Compliance program 30 years 2 years B.A. Economics, lona Officer • Regulatory compliance, trade compliance, and Code of College Ethics Investment Management Professionals Drawing from their collective expertise, the Investment Management Team develops and implements strategies for the County based on a thorough, well-rounded analysis of investment ideas that are specific to the strategy and your investment objectives. 11IPage CM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Julie Hughes, Senior Portfolio Strategist is responsible for building and maintaining client relationships with public agencies along with participating actively in the portfolio management process. Julie has nearly three decades of finance, strategy, and client relationship management experience. Julie serves as a member of the firm's Quantitative Analysis Committee and Economic and Market Analysis Committee. Scott Prickett (CTP), Co -Chief Investment Officer, is responsible for building and maintaining client relationships with a focus on developing and enhancing client investment programs. Scott actively participates in the portfolio management process and meets with clients on a regular basis to review their accounts, portfolio activity, portfolio strategy, and financial markets. Scott has 35 years of investment industry experience focused largely on managing short-term fixed -income strategies for governmental and institutional non-profit clients. Scott serves as Co -Chair of the firm's Economic and Market Analysis Committee. Jayson Schmitt, CFA, Co -Chief Investment Officer, and his colleagues on the Investment Management Team employ our research -based methods to structure investment solutions that address the County's dual needs for liquidity and return, implement the portfolios' strategies in a customized manner, and conduct securities transactions in the accounts. Jayson holds the designation of Chartered Financial Analyst and serves as a member of the firm's Executive Committee, Co -Chair of the Quantitative Analysis and Multi -Asset Class Committees and provides daily oversight of the investment management process. Relationship Management and Client Service Ben Mendenhall, Senior Relationship Manager, is a Senior Relationship Manager and joined the firm in 2022 with 16 years of investment management experience. He has worked with the Colorado local governments for over 12 years. Ben maintains existing relationships and develops new ones, and his area of focus is on the development of client relationships in the Rocky Mountain Region. Previously, Ben was a VP of Investment Advisory Services for Public Trust Advisors where he was responsible for relationship management, LGIP development and service, client education, portfolio strategies and reviews. Prior to working for Public Trust Advisors, he worked for Public Financial Management (PFM) as a Senior Analyst, serving in a variety of client facing roles. Ben is a graduate of the University of Rhode Island with a B.S. in Business Management & Finance. He holds the FIRNA Series 65 license. Stacey Alderson, CTP, Client Service Director will provide support in serving the County and its staff. Stacey is in our Denver office and will be accessible as a local resource for any calls or in -person visits. Your relationship managers will work closely with you — reviewing investment policies, assisting with custodial relationships, and providing investment training among other things. Chandler's client service and marketing teams provide responsive service and follow-through to completion for any pressing or immediate needs of the County and its staff. Our client service personnel are adept at handling the non - investment needs of the engagement and will escalate any issues and route them through the correct channels, if necessary. Compliance and Oversight The firm's CEO, Martin Cassell (CFA) provides oversight of all aspects of the firm and leads the investment team and implementation process of our proprietary quantitative models and strategy. 12IPage GM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO The firm's President, Nicole Dragoo, JD (IACCP), is responsible for the firm's strategy and administration and oversees the compliance and operations departments. She also leads the onboarding process of new client accounts and heads a team that communicates effectively with accountants, custodians, and administrators during the transition period and for the duration of the relationship. Joseph Kolinsky, Chief Compliance Officer, leads the day-to-day compliance requirements, regulatory filings for the firm, and Code of Ethics implementation and training. For detailed r�sum�s of all team members, please see the Professional Biographies in the Appendix. Management and Staffing Plan. Chandler's client service is a core value and firm priority. Chandler manages portfolios in a team environment ensuring that all investment team members and client service personnel are familiar with your portfolio. This team approach ensures that there will always be professionals available who are knowledgeable about your portfolio management needs and provide continuity of the investment program. We understand the County's investment program is unique, and we work with staff to implement a process that suits your needs. As of June 30, 2022, the firm's six CFA -level investment team members, three analysts, and five portfolio strategists manage 204 institutional client relationships totaling $26.8 billion, for an average of under 30 relationships per investment professional. In general, we believe that the concept of the average number of accounts per investment professional is not representative of the distribution of work within our investment process. The successful implementation of the team's investment process is not dependent upon any one individual; in fact, the responsibilities and action items for each account are distributed across the entire team. In addition, all of our investment personnel have research, trading, and analytic responsibilities, which benefit all of our clients' accounts. While we do not have a fixed maximum of accounts or assets under management per investment professional, we have a comprehensive plan in place to add staff members as we add assets under management. Our goal is to maintain the high level of performance and service that is one of the hallmarks of our firm. Over the last 12 months, Chandler has added four (4) members to the investment team to ensure client portfolios continue to receive our high standard of care. We place the utmost value in our relationships with clients. We will maintain consistent staffing with your assigned team and dedicate the resources necessary to ensure the highest level of service. 13 'Page CA CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO In addition to the firm's SEC registration, the below members of Chandler's Investment Management Team are registered representatives: Chandler Registered Representatives Investment Adviser Representative CRP Number Martin D. Cassell, CFA Stephen Church Daniel Delaney, CFA William Dennehy II, CFA Julie K. Hughes° rr, Genevieve C. Lynkiewicz, CFA Benjamin Mendenhall M.., Karl Meng Aneil Murthy Aaron Nail Carlos Oblites9 Donald Penner Ted J. Piorkowski, CFA Scott D. Prickett, CTP Kara Raynor -Sanchez Alayne Sampson Jayson Schmitt, CFA 4330905 6878939 7378402 2397527 5397196, 4462193 5094867 5198403 5745037 .> 6761656 5350645'1w,, 4591719 1857510 1901448 7615064.E 5435009 4892847 For detailed r�sum�s of all team members, please see the Professional Biographies in the Appendix. 2.4 Have any of the above personnel ever been investigated for alleged improper, fraudulent, or unfair activities related to the sale of securities? If so, please provide details. No Chandler Asset Management employees have been investigated for alleged improper, fraudulent, or unfair activities related to the sale of securities. 2.5 State whether there has been any turnover of key personnel in the firm or additions to staff in the past two years. Chandler added six (6) investment team members in the last two years, as well as some key executive team hires. Joseph Kolinsky, hired as Compliance Manager in January 2020 now serves as Chief Compliance Officer. Other additions to our staff include Ryan Tauber, Managing Director of Business Development, who, since 2020, oversees the firm's sales, marketing, and client service efforts. Chandler continues to create new positions to accommodate growing business demands. Throughout the firm's history, the turnover of professional staff has been significantly low. Three investment team members left the firm in the last three years. 14I. e CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Chandler Staff Turnover from 2020-2022 Year to Date Total 2020 31 2021 32 2022 42 Staff Added 3 7 10 Staff Lost 1 6 2 2.6 What efforts does your firm make to keep its investment professionals informed of developments relevant to government investment managers? We provide our investment professionals with the training they need to remain up to date on changes to the financial markets as well as evolving practices that impact our local government clients. Many of our investment professionals have demonstrated their understanding of and commitment to portfolio management by earning industry credentials, such as the Chartered Financial Analyst (CFA) the Certified Treasury Professional (CTP), and a number of Financial Industry Regulatory Authority (FINRA) licenses that require continuing education. Other team members are working to achieve these designations, and all employees are encouraged and supported to achieve these and other industry certifications or training that will assist them in their careers and ensure our clients have access to best -in -class professionals. Our compliance professionals monitor regulatory changes affecting local governments and stay up to date on SEC updates and legislative changes. Senior members of Chandler's compliance team have earned the designation of NRS Investment Adviser Certified Compliance Professional (IACCP) and ensure the firm is prepared to address the ever-changing rules, regulations, best practices, and new trends of financial industry compliance through additional and ongoing education. In addition, the firm engages an outside consultant to assist us with the complex practice of regulatory compliance as it applies to varied aspects of the management of public funds. In addition to the ongoing training received by our investment and compliance professionals, Chandler is deeply involved with the Government Finance Officers Association (GFOA). Our investment professionals as well as members of our compliance and operations teams are guided by the GFOA's publications and best practices regarding investment management, compliance, and Government Accounting Standards Board (GASB) reporting for public agencies. Our investment and client service professionals serve as committee members and are active participants, sponsors, and speakers at national and regional associations that develop recommended best practices and training curricula. Through our involvement and participation with these organizations, Chandler's professionals stay informed about current themes and relevant topics affecting the constituents of the member entities. Martin Cassell, CFA, CEO, sat on the GFOA's Committee on Treasury and Investment Management. This committee tracks new developments in cash management and develops best practices for government officials at all levels. Other senior investment team members participate in the Committee on Retirement and Benefits Administration (CORBA), which tracks new industry practices, regulatory and legislative developments, and issues best practices to assist public pension and personnel officers in effectively managing state and local retirement funds and employee benefits. 15 IPage CAN CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO 2.7 Identify your firm's compensation arrangement for professional staff. Describe any circumstances under which your firm or any consultant in your firm receives compensation or finder's fees from investment managers. Provide copies of your conflict of interest and code of conduct policies. Chandler has a comprehensive compensation policy for our investment professionals designed to align with our clients' interests. This policy includes incentives based on individual contributions to our clients' success and efforts toward building an enduring firm with a long-term culture of shared success, rather than utilizing performance -based compensation. Individual base salaries are competitive, and commensurate with experience, education, and roles and responsibilities. Furthermore, all employees participate in the firm's Employee Stock Option Plan ("ESOP") and have a proportionate share in the ownership of the firm. Chandler's senior leadership team receives competitive base salaries and annual discretionary bonuses based on individual contributions to the firm's overall success. Key principals of the firm are also majority owners and have a proportionate share in the firm that is greater than the employee participation share of the ESOP Trust. 3. INVESTMENT MANAGEMENT APPROACH 3.1 Describe your anticipated role and what specific services you would provide as investment advisor. Does your firm have the capability of soliciting competitive bids on investment purchases? Chandler's anticipated role as investment advisor to the County is to manage not only the portfolio but also the overall investment program. At Chandler, not only investment management, but also investment operations, reporting, client service, and compliance are implemented in a team environment to integrate all aspects of your investment program efficiently and effectively, and includes the following: Comprehensive Portfolio Management. Chandler will partner with the County to provide investment management pursuant to the prudent investor standard of care required as a co -fiduciary. Team members apply their years of investment experience to structure portfolios designed to achieve our clients' objectives. After establishing appropriate benchmarks in accordance with your objectives and risk profile, we will implement an investment program designed to generate competitive results by: • Effectively monitoring and managing portfolio risk. • Managing the portfolio in strict compliance with the investment policy. • Rebalancing the portfolio as needed to maintain the appropriate risk profile. • Employing a proprietary, quantitative, and qualitative based credit analysis process of portfolio investments and potential investments. • Using our proprietary Horizon Analysis Model to determine the optimal portfolio structure for the current interest rate and yield curve environment. • Working with you to develop reasonable cash flow projections to identify what funds need to be available in the next six to twelve months. • Maintaining an ongoing dialogue with you through periodic investment meetings and frequent telephone contact with your staff. Investment Policy Review. We understand that the investment policy is crucial to the development and maintenance of a public agency investment program. Our partnership with you will begin with a 16 IPage CM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO thorough review of your investment policy and overall strategy. We will recommend updates and revisions as needed. We will then review your policy at least annually and recommend revisions when necessary. Portfolio Accounting and Reporting. You will receive a monthly report that includes a management summary of portfolio characteristics, policy compliance, and performance, as well as full accounting details. Monthly reports are available no later than the third business day following month -end. You will also receive a quarterly report in a format designed to facilitate discussion between our investment personnel and your staff. Reports will be prepared in accordance with state law and the Governmental Accounting Standards Board (GASB) and are compiled to meet your specific needs. Chandler Asset Management claims compliance with the Global Investment Performance Standards (GIPS®) and prepares and presents its performance in compliance with these standards. Chandler is independently verified by ACA Performance Services for firm -wide GIPS compliance. Online Access. Periodic reports as well as holdings and transaction reports will be available online through our Chandler Client Portal, a secure web portal. Details of securities held can be downloaded directly into your internal reports through the portal. Compliance Monitoring. We will monitor your portfolio to ensure compliance with your investment policy, state statutes and any additional directives. A summary report of compliance with your investment policy will be included with your monthly report. Competitive Transaction Executions, Settlement, and Documentation. We execute all investment transactions on a competitive basis and document the quotes received. All trades will be settled at your custodian bank using delivery -versus -payment (DVP) procedures. Client Education. Chandler professionals serve as faculty members for national and regional associations, such as the Government Finance Officers Association (GFOA). We will provide educational presentations for your staff, management, and other officials. Communication. We will keep you fully informed of investment strategies, market conditions and developments that are relevant to your investment program. We will meet with you as frequently as you prefer, and our investment professionals will also be available by phone during business hours. Competitive Bids. The Investment Management Team maintains an active relationship with the broker/dealer community in order to promote an ongoing flow of market information and to execute trades for our clients at competitive prices. On a given day, various factors may combine to generate the best price fora given transaction, including current dealer inventories, dealer profit/loss positions, and individual dealer sentiments about the market. No one dealer will consistently provide best execution. For that reason, we consistently place several dealers in competition and continuously monitor and compare inventories and prices. Given that all of our transactions are executed using "delivery -versus -payment" (DVP) procedures, the firm's broker/dealer selection and retention process centers primarily on transactional risk. Thus, our internal criteria for reviewing and monitoring broker/dealers for approval and retention include: • Competitive pricing • Trade execution efficiency • Consistency of coverage 17 IPage CM CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO • Quality and breadth of product inventory • Willingness to make a two-way market We monitor financial news for any indication of financial weakness or diminishing participation in our markets. In addition, we are concerned with broker/dealer integrity and capitalization. The Financial Industry Regulatory Authority (FINRA) provides an on-line BrokerCheck System, which we use to review the credentials and regulatory background of each broker/dealer firm and their employees with whom we trade. 3.2 Describe the level of involvement you anticipate with county staff and what information you require from county staff on a daily, monthly, or other basis to execute investment advisory responsibilities (e.g., confirmation of cash projections, receipt of new monies, and knowledge of pending county funding requirements). Describe the daily procedures for portfolio review and client contact. We are available to provide a level of involvement that is appropriate for you. Scott, Julie, and Stacey will work with you to establish an understanding of the information you need on a timely basis. Our outreach will include emails, telephone calls, and personal visits that will help us understand the information you need to assist you in communicating effectively with us. We will not overburden you with questions or requests. Your team will be available to you every day. Typically, Julie, Scott, or Stacey will be able to speak with you immediately; if not, our callback will be no later than the close of business on the same day. Initially, we will be in contact often while the details of the account set-up are finalized. For a non - discretionary relationship (the client would like to maintain control as to whether or not to purchase a certain security at a given time), Julie or Scott will call to discuss our recommendations for your approval before making the trade. On a daily basis, investment team members will compare the characteristics of each of your portfolios to its defined target structure, using our proprietary system. The system compiles account data and highlights how the portfolio differs from its target duration, term structure, and sector allocation. Our investment team then reviews and analyzes the differences. If the team decides that a change in portfolio structure would benefit the County, Julie or Scott will call to discuss our recommendations. If you concur, we will execute the necessary transactions. 3.3 Briefly describe your firm's investment management philosophy. Provide specific detail on how it will apply to managing governmental and yield -based portfolios. What are your primary strategies for adding value? We believe that through effective risk management, we can enhance the potential for higher total returns for risk -conscious clients while maintaining their shared primary objectives of safety and liquidity. Our approach utilizes investment processes and strategies we have developed over three decades, and focuses on: • Safety of principals; • Appropriate levels of liquidity; • Diversification of risk; • Compliance with policies, legal requirements, and risk/return objectives; and • Active management to generate investment income and total return. 18 'Page Request for Proposals (B2200146) for nt CHANDLER Investment Advisor Services Ana ASSET MANAGEMENT WELD COUNTY, COLORADO We implement this philosophy by structuring investment portfolios with the goal of achieving performance that consistently exceeds the returns of a selected market benchmark over a market cycle, while always maintaining each client's tolerance for risk. We reduce exposure to market risk by diversifying the portfolio by issuer and security type, as well as by establishing and maintaining a target portfolio duration that is consistent with the investment objectives. Chandler's singular focus stems from the investment philosophy of our clients that prioritizes safety and liquidity above chasing returns that may put their principal at increased risk. As a result of this focus, we take a conservative approach regarding all aspects of the investment and portfolio management process. Our methods for developing the investment objectives and constraints for our clients is customized after an extensive review and thorough understanding of the investment policy, risk tolerances, as well as the current and expected mandates of the client's specially purposed funds. Primary Strategies for Adding Value Chandler's pro -active portfolio management, diligent security analysis, and prudent attention to cash flow needs add value to client portfolios and enhance the consistent returns generated over time. Our approach to structuring the portfolios is designed to fulfill the County's requirements in a way that addresses specific investment needs, and focuses on the following key elements: Duration Management — We strive to maintain duration (the portfolio's price sensitivity to changes in interest rates) within a defined range that reflects the County's return requirements and acceptable volatility as indicated by a benchmark that reflects the risk parameters and expected return. Duration is the largest determinant of risk and return. We attempt to minimize the impact of the duration decision on return volatility by limiting duration to within a +1- 20% duration band around the target (benchmark) duration. We have observed that longer -duration portfolios have historically outperformed shorter duration portfolios over long-term investment horizons. We will work with the County to identify an appropriate duration target that takes advantage of longer maturity investments with higher yields, while limiting volatility, and providing for needed liquidity. Chandler's investment management team does not try to time interest rates and keeps the overall interest rate risk sensitivity of our clients' portfolios close to that of the benchmark. An optimal term structure is based on our proprietary analysis and a probability -weighted forward -looking forecast of various interest rate scenarios that may occur at the six- to twelve-month horizon date. Sector Allocation— Our sector allocation process is based on the belief that portfolios are more robust and prepared for unforeseen events if they have a well -diversified exposure to high quality fixed income securities. Using the output of the Sector Committee, we will determine the allocation to asset classes that we believe will provide the best economic opportunities and protection for the portfolio. We are able to add considerable value through rotating sectors as market conditions evolve and our outlook changes, thus identifying best relative value at time of purchase in order to capitalize on current market opportunities. Term Structure— Utilizing the output from the Economic and Market Analysis Committee in conjunction with the Horizon Analysis Model, the term structure for the portfolio is determined with the objective of finding a structure that prioritizes the protection of the portfolio and performs well under both anticipated and unanticipated yield curve shifts over a six-month horizon. Given the 19 'Page CAS CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO constantly evolving market dynamics and changing interest rates, the portfolio may have a "laddered" structure, with equal allocations across permitted maturities; a "barbell" structure, with maturities concentrated in short and long maturities; a "bullet" structure, with maturities concentrated around the target duration; or some combination of all three. As interest rates evolve, the Chandler team alters the maturity distribution of the portfolio based on the prevailing market conditions. Security Selection— Once the team has determined the percentage of the portfolio in any duration range or security type, individual securities are purchased to complete the portfolio structure. Chandler's investment team closely follows trends in the new issue market to take advantage of the cyclical swings in issuance in order to obtain attractive spreads over the risk -free Treasury rate. The seasoned professionals at Chandler are also well versed in the technical differences between various names in the investment universe, and frequently adjust the underlying name and sector exposure to take advantage of market anomalies only a skilled investor can consistently identify. Securities are subjected to a rigorous review process, including fundamental credit analysis, as well as quantitative analysis using proprietary tools. Our investment professionals recommend securities from an Approved Issuer List based on relative value considerations. In addition, our Credit Committee seeks to identify both improving and deteriorating credits so we can work to reposition client portfolios by seeking favorable factors and avoiding detrimental determinants not yet understood by the majority of market participants. Analyzing the credit worthiness of individual issuers to enhance portfolio yields while minimizing exposure to credit and downgrade risk is a key element in mitigating risk and adding value in our clients' portfolios. Active Management of Individual Securities — To maintain the optimal structure and the objective of safetyl of principal and risk -adjusted returns over a market cycle, Chandler utilizes active management of the investment portfolio. With this approach, a security may be sold or replaced prior to maturity to take advantage of market conditions, generate liquidity, mitigate risk, or to enhance the return of the portfolio. We are also able to take advantage of the repricing into the current higher interest rate environment. The net economic benefit to the County is the sole consideration for purchasing/swapping/selling securities for the portfolio. Competitive Execution. We recognize our duty to provide value to our clients and ensure the quality of our services as a fiduciary. The County's staff is assured that through Chandler's best execution practices, it is receiving competitive, institutional pricing on transactions, as the firm seeks a minimum of three quotes per trade. The practice of competitively bidding for transactions results in an incremental net financial advantage for our clients over time and is an additional source of value in retaining Chandler as investment manager. This competitive process can be evidenced on daily trade tickets viewable on the Chandler Client Portal. 3.4 What is your firm's experience in developing investment policies, internal procedures, and portfolio strategies for public sector clients? We understand that an investment policy is crucial to the development and maintenance of a public agency's investment program. We begin each relationship with a thorough review of each client's investment policy, during which we make recommendations and use them to formalize the investment 1 While our conservative investment approach promotes safety, investing in securities carries varying degrees of risk and we cannot guarantee safety of principal. 20 IPage CAt CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO mandate for each client's portfolio(s). Suggestions are meant to provide clarification, increase return potential, and improve risk management. We have written or revised investment policies for almost all of our government clients, and we customize each policy to mirror the client's specific objectives and tolerances. We will customize your policy to reflect: • Colorado Revised Statutes • The County's Investment Policy • Specific County directives and risk tolerances • Industry best practices as identified by the Government Finance Officers' Association and the Association of Public Treasurers of the United States and Canada Chandler's Best Practices With over three decades of experience serving public agencies, we are well -versed in the Colorado Revised Statutes as it applies to public agency investing and are actively involved with associations that develop recommended best investment practices. including the Government Finance Officers Association (GFOA). In reviewing investment policies, we look for clearly defined portfolio objectives and constraints. At the start of the engagement, we will consult with you to understand and quantify your investment objectives, risk profile, and expected outcomes. We will then document what we have learned. In that way, our strategy and your policy complement each other. Once the investment policy is approved, it becomes the operating guideline for the portfolio. In addition, we will review your investment policy annually to ensure that your policy is updated as your objectives and cash flow requirements change over time. The policies we draft state in clear, unambiguous language the risks that are acceptable to a client and the investment strategies that we may undertake to achieve the client's goals. Our policy review includes, at a minimum, the following areas: Scope of the policy that defines which funds are covered by the policy Investment objectives that clearly define how safety, liquidity, and return will be attained Standard of care (Prudent Expert) Delegation of authority Ethics and conflicts of interest Authorized investments Management of market and credit risk Safekeeping and custody of securities Reporting requirements Performance standards 3.5 Describe the types of investment research utilized and the methods for making investment decisions, including maturity and selection. Describe your firm's in-house research capabilities. Do you use outside sources regularly? Describe your credit review process. Do you assign credit research to specialists? What percentage of your research is conducted in-house? Describe your firm's research capability. Chandler devotes considerable resources to enhancing our own in-house capabilities and evaluating research from outside sources that we incorporate into our own proprietary processes. Aided by inputs from the different investment committees, decisions are made by the investment team regarding 21IPage (',,,CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO duration positioning, sector allocation, term structure, and issue selection within the firm's macro view of the economic environment and broad -based view on interest rates and leading economic indicators. The investment team then incorporates these decisions as they apply to each individual portfolio. As our primary focus is on the management of fixed income securities for public agencies, the firm's analytical rigor is dedicated to the investment types we purchase on behalf of our clients —US Treasuries, Federal Agencies, corporate bonds, commercial paper, negotiable CDs, asset-backed/mortgage-backed securities, as well as the value identified between sectors and individual issuers. Chandler conducts 100% of its research in house. Internally developed, proprietary tools such as our Horizon Analysis Model and credit review/security selection provide a quantitative foundation for Chandler's portfolio construction process. In addition, the investment management team subscribes to a variety of private research providers including BCA Research, Oxford Economics, Egan Jones, and CreditSights to augment the overall research efforts of the firm. The team keeps abreast of sell -side research from a broad group of domestic and international investment banks. These tools not only provide data for our investment processes but also ensures that our clients have access to the most current and relevant market information. Chandler's professionals also conduct research projects on an ad hoc basis on issues concerning our industry and our clients, such as changes in the brokerage world, studies on how legislative changes impact our clients, and research on new sectors or investment structures as appropriate for our clients' portfolios. Proprietary Tools and Best -in -Class Resources for Portfolio Constructions Chandler's proprietary Horizon Analysis Model is the quantitative foundation for the portfolio construction process. The model enables our portfolio management team to integrate their research into the portfolio management process in a disciplined and repeatable way. Inputs to the model include: • current yields on Treasury, agency, and corporate securities; • specific client constraints, such as maturity restrictions and maximum sector exposure; and • nine different probability -weighted forecasted interest rate scenarios that may occur at the six-month horizon date. Our analysis of current macroeconomic conditions is one of the factors we consider as we develop the nine scenarios that comprise the third input to the model. Chandler's Investment Process OUR INVESTMENT PROCESS OUR PROPRIETARY QUANTITATIVE PROCESS SUGGESTS OPTIMAL PORTFOLIO STRtJCTtrJPFc INPUT AND CLIENT CONSTRAINTS 'N Yield Curves r Constraints Scenarios HORIZON ANALYSIS MODEL A combination of our qualitative insight and quantitative proprietary algorithms PORTFOLIO STRUCTURE • Duration • Term Structure • Sector Allocation • Security Selection vi S�cate9v Mesta' n QualitativeA a and quantitative analysis and n review 3 tie fee SECURITY SELECTION Quantitative Ranking •/ Qualitative Analysis •i Relative Value Analysis 221 Page CA CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Through an iterative process, the model generates the "optimal portfolio structure" (duration, maturity distribution, and sector allocation), which we define as the portfolio that achieves a return greater than the benchmark in each of the nine scenarios That is, the model generates a portfolio structure that we expect will outperform the portfolio's benchmark over a wide range of possible future interest rate movements The Investment Team then evaluates the optimal portfolio structure and using their expertise and judgement, may make adjustments as they begin the construction of the portfolio This combination of a rigorous quantitative structure and experienced qualitative oversight is a hallmark of all of Chandler's portfolio management activities Periodic Rebalancing — With the passage of time, portfolio characteristics tend to drift away from the desired structure For that reason, the team reruns the Horizon Analysis Model monthly, reevaluates the optimal portfolio structure and rebalances to obtain the desired sector allocation and duration target as market conditions change In addition, the benchmarks used by our clients for performance measurement are reconstituted monthly, therefore, we realign our portfolios with these benchmarks As part of our active management approach, we will also rebalance when we find securities of superior value in terms of expected return or reduced risk or to adjust the credit quality of a holding for the portfolio Credit Analysis and Security Selection Chandler conducts credit research in a team environment comprised of investment professionals as part of the firm's Credit Committee William Dennehy, CFA, Co -CIO is the chair of the Credit Committee which also includes additional members of the investment team The firm's proprietary credit research process identifies stable and improving credits to include in client portfolios Although the Nationally Recognized Statistical Rating Organizations ("NRSROs") typically determine the initial eligibility of a security, Chandler does not rely on these ratings to determine whether a security is suitable for a Chandler portfolio Chandler's Credit Committee, with input from the entire investment team further vets the suitability of an investment based on our own internal research and a thorough understanding of each client's investment objectives and risk tolerances This combination of qualitative and quantitative analysis enables the team to identify and invest in securities that are consistent with our clients' objectives of safety, liquidity, and return The dynamic nature of the process also provides the team with the ability to detect weak and deteriorating credits, which may be removed from client portfolios and Chandler's Approved Issuer List In determining the suitability of a security, the Credit Committee analyzes company fundamentals with a focus on relative balance sheet strength and the overall earnings outlook of the issuer, paired with Chandler's view of the forward -looking macro -economic environment After the fundamental outlook of an issuer has been ascertained, the Credit Committee focuses on the relative value of current and historical spreads of both the issuer and its industry sector Chandler's internal credit process is designed to identify and evaluate changing fundamentals and the current relative value of issuers versus sector peers The Credit Committee meets regularly to rank corporate issuers into three tiers and categorizes those securities based on individual client risk tolerance and policy guidelines Each sector and issuer are reviewed at a minimum of once per quarter, or four times per year The goal is to be proactive in identifying and investing in stable and improving credits, and in avoiding deteriorating credits 23 IPage `,,,CHANDLER ASSE I MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Chandler's Credit Review Process r CREDIT COMMITTEE • Evaluate fundan ental • Determine reatwe vows • Segment ;Suers into three ti • Estabrisn si4ratify by strott , J Issuer -specific fundamental analysis 1l Industry research and fundamental 1 analysis Macro- economic research • Research reports • Relative value analysis • Investment recommendations • Maintains Approved Issuer List r In addition to the formal Credit Committee meetings, all credits are monitored on a continuous basis. The Credit Committee monitors the overall news flow on each issuer on our approved list (i.e., earnings, press releases, management presentations or conferences, ratings changes, etc.). The gathered information is distributed to the entire investment management team daily. In the event that the fundamentals of the underlying security change, the Credit Committee may act to add or remove the issuer from our approved credit list or move it within the appropriate tier. r 1 INVESTMENT COMMITTEE & CIO REVIEW _1 Chandler Strategies In addition to our internal research tools and capabilities, the following external systems and software support our trading, portfolio accounting and client reporting: • PAM for Securities Accounting system (Princeton Financial Systems)- Main source of record where all portfolio transactions are stored. Holdings information are based on the transactions entered. Also stores SM F records, pricing, ratings, performance calculations, and other supporting data. • SQL Database- Stores enterprise operational data such as account information, reporting/configuration, credit/index information, etc. Also stores copies of PAM data. Main source of information for 95% of our reporting. Remaining information comes from PAM, Access, or Bloomberg AIM reports. • SQL Reporting/Report Manager- Main application that creates, automates reports, and displays reports. • Bloomberg AIM - Order Management System. Imports holdings information from PAM and sends trading transactions to PAM. Also gets trade ticketing information, allocations, OASYS, settlement instructions enrichment. Compliance system used for pre -trade, post -trade, and end -of -day compliance testing and straight -through processing of investment transactions. • Bloomberg AIM - Investment Manager. The Bloomberg AIM system provides seamless data integration that compliance, as well as post -trade automation such as trade and security master file (SMF) data automatically sent to our accounting system. Its compliance monitoring features will calculate and monitor asset class exposure, as well as issuer size and concentration limits, as well as compliance with the County's investment guidelines and legal requirements. • Effects of Security Purchases/Sales. Bloomberg AIM also allows the portfolio manager to test the effects that new securities will have on an existing portfolio. For example, the team can propose a trade in Bloomberg AIM, and determine what impact the position will have on the portfolio's overall duration. In addition, we can perform an analysis on how a portfolio will be affected given a specified 24(PagE Request for Proposals (62200146) for ®CHANDLER Investment Advisor Services ASSET MANAGEMENT WELD COUNTY, COLORADO -. .... - a s.l o- v .,H. i .c c , r ,„, . r _ ,r .1 , change in interest rates to ensure the portfolio will continue to meet the objectives of the portfolio We also can see the impact of security transactions on the portfolio not only from a portfolio management standpoint but also the implications to the accounting such as the gain/loss of a security sale Electra Reconciliation System and Data Retrieval Services — Custodian to PAM reconciliation system Gathers and consolidates bank and manager data each night/morning, as it becomes available OASYS- Product by OMGEO that communicates trade allocations to other participating OASYS brokers Confirm/Affirm- Product by OMGEO where the details of trades are communicated between the broker and Chandler to achieve settlement This helps streamline settlements and notifies parties when trades details do not match Salesforce CRM—Contact management, portfolio settings, report distribution settings The County is not required to purchase any additional programs or software that is utilized for services under this engagement, relieving the need to allocate capital for portfolio optimization, policy compliance, financial reporting, and other crucial aspects of managing your funds 3 6 Discuss your prognosis of interest rates (both short and long-term) over the next two years and the investment strategy you would currently recommend for the county over the next two years. Briefly discuss investment alternatives available to the county currently on the market in terms of rate of return and relative risks. Although we do not profess the capability to consistently predict the timing, direction, and magnitude of interest rates, we believe short-term interest rates will continue to follow the path of the Federal Reserve (the "Fed") The Fed has clearly indicated its intention to raise the target Fed Funds rate until inflation has returned to levels more consistent with their mandate Therefore, we believe short-term rates will continue to rise along with Fed rate hikes this year As the economy slows and inflationary pressures subside, we believe the Fed will be able to implement less aggressive rate hikes As economic conditions slow down into next year, we expect rate levels to stabilize As the Fed ramps up quantitative tightening to reduce the balance sheet by letting $95 billion/month in US Treasuries and Agency mortgage -backed securities mature without reinvestment, this may put upward pressure on the longer end of the yield curve However, this effect may be counterbalanced by inflation expectations declining with tighter financial conditions The yield curve is currently inverted between 2 -year and 10 -year treasury rates Historically, an inverted curve is consistent with slower economic growth and typically does not persist for a prolonged period of time Therefore, as we move through the economic cycle, we should expect the curve to gradually return to a normal upward -sloping shape with lower rates on the short end and relatively higher rates on the longer end We believe the best way to provide superior performance over the long -run is to maintain discipline with the investment strategy that best suits the County's risk tolerance We will discuss various strategies in the context of market conditions and the County's risk tolerance In the current market, government securities are available at rates above 4% in the 2-5- year part of the curve Credit instruments such as high quality corporate bonds and commercial paper are available at attractive spreads to government securities, however, credit risk exists and must be analyzed, monitored, and managed 37 Provide performance data for similar accounts under management with comparative industry performance data for the last year, five-year, and ten-year period. Please show annualized quarterly 'Page e CA CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO returns, gross of all management fees. All performance numbers must be presented in accordance with the APT US&C. Chandler reports GIPS -compliant returns for three strategies most commonly used by public agencies that are consistent with County's investment policy: • Chandler Ultra Short (0 -3 -year) strategy • Chandler Limited Maturity (1 -3 -year) strategy • Chandler Short Term Bond (1 -5 -year) strategy Explicit information on the performance of these comparable accounts is provided below. Chandler Composite Performance — Gross and Net of Fees -1.75% 0.37% 1.00% 0.69% 3.53% Chandler Ultra -Short (net) ICE BofA 0-3 Year US Treasury Index -1.27% 0.52% 1.08% 0.74% 3.37% Chandler Limited Maturity (net) -3.37% ICE BofA 1-3 Year US Treasury Index 0.16% 0.88% 0.74% 3.98% -3.30% 0.24% 0.94% 0.79% 3.95% Chandler Short -Term Bond (net) -4.79% ICE BofA 1-5 Year US Treasury & Agency Index -0.01% 0.84% 0.86% 3.40% -4.60% 0.04% 0.92% 0.90% 3.40% Based on Chandler's Ultra -Short, Limited Maturity, and Short -Term Bond composites as of 6/30/2022. Performance results are presented gross of fees. The performance has been calculated using historical composite performance. Gross performance does not reflect payment of advisory fees and other expenses which will reduce performance. Past performance is not a guarantee of future results. All investment strategies have the potential for profit or loss. Market conditions or economic factors may alter the performance and results of a portfolio. Investment advisory fees are disclosed in the firm's form AD V, Part 2A. Performance for periods greater than one year is annualized. Please see GIPS Composite Reports and important disclosures in the Appendix. For one-on-one presentation only. 'Page e CA CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Additionally, we provided our GIPS Composite Reports and Quarterly Returns Report for our Ultra -Short, Limited Maturity, and Short -Term strategies in the Appendix 4. REPORTING 4.1 Describe the investment accounting and reporting system used, including your online reporting capabilities Chandler utilizes a third -party accounting software called PAM for Investments It is a State Street product that performs investment accounting and reporting including performance measurement We have been using PAM since 1995 and over the years have been able to identify areas for improvement within the product and have seen said improvements incorporated into later releases Using PAM as the investment book of record for our clients, we generate comprehensive monthly statements and performance reports, which clients receive no later than the third business day following month -end Our standard reports currently include ® Portfolio total rate of return compared to the benchmark return for periods of one month, the most recent quarter, year to date, one year, three years, five years, ten years, and since inception • Purchase yields To ensure integrity, we receive daily pricing of securities from Interactive Data Corporation, Inc (IDC) In the rare instance that a security is not priced by IDC, we use an alternative pricing source, such as TRACE, Bloomberg, custodian valuation, etc, to determine reasonable fair market value Our operations team also performs daily reconciliation of transactions and cash balances with our clients' custodians We are able to provide comprehensive reporting that will be tailored to meet the County's unique needs, as well as meet the demand of the marketplace While our performance measurement software and data sources are from outside vendors, our reporting capabilities are based on a proprietary reporting tool, so we are able to customize reports for our clients We have provided samples of reports in the Appendix Online Access In addition, the Chandler Client Portal, a secure web portal, offers online access and the ability to download daily transactions and holdings, as well as historical monthly and quarterly statements and reports Reports can be downloaded in Excel format that can be mapped to your internal reporting requirements Access to the Chandler Client Portal is available to individual contacts selected by the client 4.2 Describe your firm's knowledge of and ability to assist in the compliance with GASB 40 and 72. Chandler is knowledgeable and able to assist the County with GASB 40 and 72 reporting Chandler's investment and operations professionals remain dedicated to staying in front of all GASB pronouncements, interpretations, and implementation guidelines as they affect our government clients from a reporting and compliance perspective We will develop reporting procedures in line with the County's needs and objectives Reports will be prepared in accordance with state law and the Governmental Accounting Standards Board (GASB) and are compiled to meet your specific needs Our reporting is designed to provide all the information needed to book earnings monthly, track investments, and prepare annual financial statements We provide statements to fulfill their GASB 40 and GASB 72 requirements Our reporting is designed to provide all the information needed to book earnings monthly, track investments, and prepare annual financial statements 27 IPage Request for Proposals (B2200146) for CA CHANDLER Investment Advisor Services ASSET MANAGEMENT WELD COUNTY, COLORADO . We provide a GASB 40 report to all governmental clients, which provides the information needed to prepare the required fiscal year-end portfolio risk assessment, and we will be able to assist the County in drafting the narratives for GASB notes We have developed a GASB 72 report which is available by fiscal year-end The GASB 72, Fair Value Measurement and Application, issued in February of 2015, requires government investments to be measured at fair market value It also requires disclosures regarding how fair value was measured, what hierarchy the investment fits into and any special valuation processes used Please see Chandler's Sample Monthly Statement and Quarterly Report in the Appendix 4 3 Describe the process the firm would go through to assist in identifying appropriate benchmarks. Based on your experience, what performance benchmark would you suggest for the county's portfolios given the current investment policy requires a short-term and a long-term benchmark? An in -person meeting will be scheduled to "kick-off' the relationship, gain an understanding of your investment objectives and constraints, and encapsulate the goals for your overall program We will conduct detailed reviews of the Investment Policy as well as the current portfolio to gain an understanding of cash flow needs, risk tolerances, permitted securities, credit profile, duration targets, and current maturity structure We will confirm that the Investment Policy provides for the County's primary objectives of safety, liquidity, and return, and incorporates all aspects of Colorado Revised Statutes related to investing public funds and may make recommendations to achieve these goals We conduct a benchmark study that analyzes the risk/return characteristics of different investment approaches and their associated benchmarks for your consideration that align with the County's investment goals The result of these discussions will be a management directive governing the investment of funds as well as additional services that may be required to support staff and treasury management operations The Chandler team has designed the entire investment process, including portfolio construction and security selection, and the selection of benchmarks to promote the objectives of safety, liquidity, and total return, or iy eld Our approach to structuring the portfolio is designed to fulfill those requirements in a way that addresses the County's specific investment needs in light of budgetary and financial realities The steps would proceed as follows Review of the Investment Policy To address safety, liquidity, and/return, we propose to conduct an in- depth review of the investment policy document governing the investment of funds to ensure alignment with Colorado Revised Statutes as well as current industry best practices Our review will take place in collaboration with your staff and will focus on • Confirming appropriate limitations of permitted investments to promote diversification and ensure safety of funds, and • Ensuring that the language of the Investment Policy offers clarity to safely capture opportunities to enhance return We encourage ongoing discussions as needed to ensure that the investment strategy and allocation of funds to diversified fixed income sectors remains consistent with your understood goals and objectives We will regularly consult with County staff on ways to expand investment guidelines with the intent to ensure they are exposed to the broadest opportunity set, while still focusing on the primary objectives of safety of principal and access to cash Development of Investment Strategies Specific to the County To enhance return, we propose to develop a customized investment strategy that addresses your return requirements, balanced with your 28IPage CA%CHNDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO preferences for managing risk. Given the current size of the County's investment portfolio, multiple strategies will be considered to meet the objectives for funds with a specific purpose. We will construct a disciplined investment approach that will serve the County through different market cycles and will allow for closely controlled risks while capturing market opportunities to enhance the performance of the portfolio. Our approach will include a review of sectors, a discussion of various fixed income strategies, and a benchmark study that is appropriate for each segment of the County's funds. Implementation of Investment Strategies. We search diligently to add value at every stage in our process. Our approach is to purposefully segment the portfolio into two components —liquidity and long-term strategies. The liquidity portfolio is customized to provide funds for disbursements as needed, in accordance with the client's direction to us. We manage the long-term portfolio, consisting of funds not currently needed for cash flow, to enhance expected earnings and long-term growth within the constraints of your risk profile and return objectives. We will work to execute the investment approach by performing daily analysis of market conditions to identify opportunities and risks, conducting in-depth credit analysis through our diligent credit review process in order to protect the County's funds from downgrades and bankruptcies, and by ensuring that we obtain the best execution for each transaction, seeking multiple price quotations on all purchases and sales in order to get the best price. Structuring the County's Portfolios. We propose to segment and diversify the County's investments in portfolios that are carefully managed through their duration structure and maturity distribution. Through portfolios of individually owned securities, the County can manage the asset allocation and maturity distribution of its portfolios based on its specific needs, objectives, and risk tolerances. While we know the County's cash flow needs are of paramount importance to its investment program, we may wish to explore with the County the benefits of allocating funds to a duration target or to a known cash flow date as a possible alternative to shorter -duration investments in LGIPs or bank balances. This structure will seek to provide liquidity from maturing securities as well as higher returns by utilizing a portfolio of securities managed to a slightly longer duration. Segmented Investment Portfolio Liquidity P • rtfolios. • Matching maturities to known expenditures • The average maturity of the portfolio is typically 1 year or less • LGIPs provide a liquidity "cushion" • Money market instruments offer diversification • May invest in: Commercial Paper - Treasury Bills Agency Discount Notes Certificates of Deposit Reserve Portfolio • Targeted generally to a higher duration to coincide with possible liabilities and enhance the potential to increase earnings • The portfolio includes securities that mature from between 0-5 years or longer, but may be concentrated from between 1-3, 1-5 years, or 1-10 years, specific to each client. • May invest in: U.S. Treasury Securities U.S. Agency Securities High Quality Credit Securities For liquidity purposes, we will explore a solution that could include using investment pools, LGIPs, or segregation into a portfolio of short -duration securities where funds are invested to a short -duration target or to a known cash flow date. 29 1 PCHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO As financial conditions and the market environment changes as they have over the last few months, we adapt our portfolio strategy to reflect the opportunities available to meet our clients' return objectives We structure our clients' portfolios to potentially achieve risk adjusted returns over a market cycle and our processes are designed to filter the market noise and search for opportunities that will achieve the long-term goals of our clients We are confident that our experienced team and time -tested processes would benefit the County's investment program through our partnership and add value to the investment program Comments on Current Investment Policy We reviewed the County's investment policy and found it to be well -written as it already encompasses many of the best practices set forth by GFOA If engaged by the County to provide investment services, we wish to explore with County staff the following topics related to the policy To enhance safety, promote diversification, and mitigate risk, establish limitations on corporate, commercial paper and municipal bond sectors and individual issuers • To enhance diversification and potential return, allow Supranationals issued by the World Bank • To limit market risk, restrict callable securities to maximum of 20% of the portfolio • Measure performance against a market benchmark selected by the County To manage risk and return, maintain the average duration of the portfolio within a narrow band relative to the selected market benchmark Comments on Current Investment Portfolio Holdings Our investment team reviewed the County's portfolio holdings If awarded the contract, we will engage the County on following considerations To increase the earnings of the portfolio, we will look for opportunities to increase exposure to corporate securities Incorporate non -financial issuers into the corporate exposure such as Microsoft and Apple • To enhance yield with securities with a maturity of less than 270 days, we will explore incorporating commercial paper into the portfolio To address risks of current portfolio, reduce exposure to callable securities A large portion of Agencies are callable Benchmark Considerations Chandler recommends starting with the ICE BofA 0-3 US Treasury Index, ICE BofA 1-3 Year US Treasury Index and ICE BofA 1-5 Year US Treasury & Agency Index benchmarks These benchmarks cover the maturity ranges that align with the maturity ranges allowed by Colorado Revised Statutes Chandler develops benchmarks that reflect the risks undertaken and should have a similar weighted average maturity and credit profile as the portfolio The benchmark should also be the basis for discussion about factors contributing to incremental outperformance of the portfolio Chandler has deep expertise in analyzing and selecting effective benchmarks for performance measurement and will undergo a collaborative process with the County's staff to select appropriate benchmarks for each of its portfolios 4 4 Describe the performance measurement software your firm uses and what type of information would be included with the performance reports. Is this software proprietary, or does your firm utilize the software of an outside vendor' If your firm uses non-proprietary software, do you have the ability to influence changes to the software to meet the demands of the marketplace' 30tPage Request for Proposals (B2200146) for CA CHANDLER Investment Advisor Services ra ASSET MANAGEMENT WELD COUNTY, COLORADO Chandler utilizes a third -party accounting software called PAM for Investments It is a State Street product that performs investment accounting and reporting including performance measurement We have been using PAM since 1995 and over the years have been able to identify areas for improvement within the product and have seen said improvements incorporated into later releases Using PAM as the investment book of record for our clients, we generate comprehensive monthly statements and performance reports, which clients receive no later than the third business day following month end Our standard reports currently include • Portfolio total rate of return compared to the benchmark return for periods of one month, the most recent quarter, year to date, one year, three years, five years, ten years and since inception • Purchase yields To ensure integrity, we receive daily pricing of securities from Interactive Data Corporation, Inc (IDC) In the rare instance that a security is not priced by IDC, we use an alternative pricing source, such as TRACE, Bloomberg, custodian valuation, etc, to determine reasonable fair market value Our operations team also performs daily reconciliation of transactions and cash balances with our clients' custodians We are able to provide comprehensive reporting that will be tailored to meet the County's unique needs, as well as meet the demand of the marketplace While our performance measurement software and data sources are from outside vendors, our reporting capabilities are based on a proprietary reporting tool, and so we are able to customize reports for our clients We have provided samples of reports in the Appendix Online Access: In addition, the Chandler Client Portal, a secure web portal, offers online a 4 5 Describe and submit samples of the reports that would be provided and their frequency. (Please include the methods and formulas used to calculate yield and performance). All reports are prepared in accordance with GAAP and GASB standards We will provide detailed monthly, quarterly, and annual reports as required by the County Chandler reports are able to be fully customized to meet your needs In 2015, Chandler made enhancements to its Client Portal, accessed through chandlerasset com, which offers secure online access and the ability to download daily transactions and holdings, as well as historical monthly statements and quarterly investment reports Reports can be downloaded in Excel format and then mapped to your internal reporting requirements Access to the Chandler Client Portal is available to individual contacts selected by the County The Portal is available 24 hours a day/7 days a week, and is also mobile -enabled Monthly Statements. Monthly statements include a summary of portfolio characteristics, performance, and full accounting details Reports may be structured to include the County's managed investments as well as its liquid funds in LGIPs and cash Chandler's consolidation of the County's accounts offers both a "broken -out" as well as an aggregated view of the County's entire investment program for increased transparency and operational efficiency This provides you with a rolled up or complete view of your investment program Reports as well as holdings, trade tickets, and historical data is available to the County via Chandler's online reporting tool, the Chandler Client Portal Monthly reports are available no later than the third business day following month -end 31IPage c� CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Portfolio Reports • Portfolio characteristics • Account Summary Detail • Sector Allocation • Maturity Distribution • Credit Quality • Total Rate of Return Monthly Portfolio Summary CM This sample report is being provided for illustrative purposes to demonstrate Chandler's reporting capabilities. References to specific securities and their characteristics are examples of securities held in a portfolio and are not intended to be, and should not be interpreted as ar offer, solicitation, or recommendation to purchase or sell any financial instrument an indication that the purchase of such securities was or will be profitable, or representative of the composition or performance of the portfolio. Accounting Reports • Security Holdings • Transactions • Amortization/Accretion • Interest Income and Accruals • Realized & Unrealized Gains and Losses • GASB 40 & 72 Annual Reporting Chandler's monthly reports conform to reporting standards established by state legal requirements and statutes governing public investments and include full asset listings including fair market value of investments, issuer, maturity date, interest rate, transactions for the period, and a description of the funds and investment programs. In addition, Chandler offers its clients transparency through a Statement of Compliance with state legal requirements and the investment policy, and a one -page summary with portfolio characteristics and total return for various period compared to market benchmarks. In addition, Chandler's reports will detail the following: • A Holdings Report, showing security description, par value, cost, book value, market value, accrued interest, gain/loss, book yield, duration, maturity, Moody's, Fitch, and S&P ratings, and percent of portfolio for each holding. • A cash flow projection from upcoming investment maturities and interest payments. • A Transaction Ledger that reports all acquisitions, dispositions, interest payments, cash contributions and withdrawals, and any other transactions for the period. • An Earned Interest Report, displaying all interest earnings, including accrued and received interest, amortization and accretion in detail form and summarized. Quarterly Reports: We present quarterly investment reports in a format designed to facilitate discussion between Chandler investment professionals and the County's staff. The report provides current economic data, portfolio characteristics and return on both an aggregate basis as well as for individual portfolios, compliance, and a summary of accounts under management using graphs, charts and illustrations in a format that is effective for management, elected officials and interested members of the public. We provide this report for our regular meetings with the County. In accordance with industry standards, the firm measures performance as time -weighted total rate of return (TRR), calculated and linked monthly, and is compared to a market total return benchmark selected by the client, in accordance with industry standards (GIPS). We also report cost and market yields on a security and portfolio basis. Formulas for Calculating Return and Yield The following are descriptions of the industry standard return and yield calculations that we employ at Chandler: 32IPage CHANDL ASSET MANAGEMENT Request for Proposals (62200146) for Investment Advisor Services WELD COUNTY, COLORADO Time -Weighted Total Rate of Return (TWTRR) — Measures the compounded rate of growth of the initial portfolio market value during the evaluation period, assuming that all cash flows are reinvested in the portfolio The time -weighted rate of return is the rate of growth that equates the beginning market value to the ending market value We calculate TWTRR monthly and link the periodic returns geometrically Total Rate of Return/Formula Time -Weighted Total Rate of Return (Total Return) — Measures the compounded rate of growth of the initial portfolio market value during the evaluation period, assuming that all cash flows are reinvested in the portfolio Total Return is the rate of growth that equates the beginning market value to the ending market value Our firm calculates Total Return monthly and links the periodic returns geometrically The following formula shows how Chandler calculates Total Rate of Return _ MV" — MV B RTR MV B Where RTR = total return MVE = ending market value, including interest accruals MVR = beginning market value, including interest accruals For periods greater than one-year, common practice is to annualize the total rate of return by raising RTR to a power equal to 1/n, where n = number of years For example, if RTR is calculated for a 5 -year period, the annualized return would be RTR raised to the power of 1/5, or 20 Total return for periods of less than one year is not annualized, in that it could be very misleading Periodic returns are geometrically linked and adjusted for cash flows We have provided our Sample Client Monthly Account Statement, Quarterly Investment Report, and GASB 40 and 72 Reports in the Appendix 4.6 How soon after the month -end and quarter -end are your reports typically available, Month -end and quarter -end reports are available by the third business day following the reporting period 5 FEES 5.1 Describe the proposed compensation for services as a flat annual fee and/or as a fee calculated based upon the dollar value of assets managed. The County's preference would be a flat annual fee but is open to other fee structures Also, describe any cap or maximum or minimum limit to the fee Chandler is pleased to provide comprehensive, full-time non -discretionary investment advisor services to the County as described herein and in the County's Scope of Services in accordance with the following fee schedule 33IPage CA CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO Proposed Fee Schedule for Weld County Assets Under Management Annual Asset Management Fee so illiun of 1% (6 b 0.05 of 1% (5 basis points) Our proposed fee schedule is all-inclusive for the services that Chandler provides, including full-time investment advisory and portfolio management services, technological resources, onboarding and implementation, online access to the Chandler Client Portal, comprehensive reporting, meetings, personal visits, educational offerings for your staff, as well as the additional treasury support services described herein in Chandler's proposal. Chandler does not charge fees on funds held in Local Government Investment Pools. Fees are firm for the entire initial contract term and the County will not be subject to any increases during this period. Our fee schedule does not include charges that the County would incur for third -party custodial services, which, as an important control in the investment process, is not provided by Chandler. Examples of the fees assessed to the County at different asset levels according to the above proposed tiered fee schedule are as follows: Total Assets Under Management Annual Fee in Basis Points Annual Fee in $ dollars 401 to'n $450 million $5001 mill€o . 4P38'b s,,, 4.22 bps 4- 0 $190,000 205;000 Fees are based on the amount of assets under management and are not based on transaction volume. Management fees will accrue as long as there are assets in the portfolio, even if there is no activity during the period. Since the firm calculates fees based on the average balance of assets under our direct management (market value including accrued interest), they will fluctuate based on portfolio value. The examples above are based on sample account sizes and should not be considered a "not to exceed" fee. Fees are charged monthly in arrears and can be debited directly from your third -party custody account. 5.2 Identify any expenses that would not be covered through this fee structure and would be required in order to implement the firm's program. Our fee schedule is asset -based; thus, all expenses are calculated from the amount of assets you wish for us to manage. In the event that the assets under our management on your behalf increase, then the fee would also increase. 5.3 If hired, will your firm receive any other form of compensation, including soft dollars, from working with this account that has not yet been received? If so, what is the form of compensation? No. The firm's revenue is derived entirely from fees for investment management and advisory services received from our clients. As of our most recent fiscal year-end, approximately 90% of the firm's revenue is from institutional accounts. Chandler does not act as a broker or dealer in securities or receive any other form of additional compensation. As an independent firm, Chandler maintains no other business affiliations, thereby avoiding any potential conflicts of interest that could interfere with our ability to 34' Page CA%CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO provide independent and unbiased advice to our clients. This structure best serves our clients, as there are no conflicts or competing demands on the best execution or upselling of services. 6. REFERENCES 6.1 Provide a list of five comparable public sector clients with portfolio sizes similar to the county, including contact persons and telephone numbers. Chandler is pleased to provide the following references for Weld County: Chandler Current Client References Client Contact Information Dates of Services AUM* Type of Account(s) City and County of Denver 201 W. Colfax Avenue, Department #1004 Denver, Colorado 80202 Caroline Hendrickson Director of Cash and Investments Ph: (720) 913-9335 caroline.ehendrickson@denvergov.org 2009 - present $399 M Management of operating funds in 1-5 year and 1- 10 year strategies Douglas County 100 Third Street, Suite 120 Castle Rock, Colorado 80104 Patrice Neef Chief Deputy Treasurer Ph: (303) 660-7409 pneef@douglas.co.us 2022 - present $342 M Management of operating funds in 0-3 year strategy E-470 Public Highway Authority 22470 E. Stephen Hogan Parkway, Suite 100 Aurora, Colorado 80018 Jason Myers, CPA Director of Finance Ph: (303) 537-3715 imVers@e-470.com 2014 - present $387 M Management of operating funds and bond reserves in 0- 3 and 1-3 year strategies Pitkin County 530 E. Main Street, Suite 302 Aspen, Colorado 81611 Ann Driggers Finance Director Ph: (970) 920-5225 ann.driggers@pitkincounty.com 2018 - present $71 M Management of operating funds in 1-3 year strategy City of Westminster 4800 W. 92nd Avenue Westminster, Colorado 80031 Bob Byerhof Treasury Manager Ph: (303) 658-2045 rbyerhof@cityofwestmnster.us 2015 - present $304 M Management of operating funds 1-3 year strategy *Chandler Asset Management Assets Under Management as of June 30, 2022. This list includes clients that have given permission to be listed. It is not known whether or not the listed clients approve or disapprove of Chandler, or the services provided. 35 I Page CA CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO 7. OTHER CONSIDERATIONS 7.1 Describe how a new client would transition to your services. Chandler will work with the County staff to ensure a seamless transition. We will develop an investment plan that considers your specific needs. The following describes the typical tasks necessary for implementation. Our process is flexible and can accommodate your timeline. It is our experience that most investment programs are ready to invest within four to eight weeks from notification of the award. Implementation Tasks Investment Program Implementation from Notice of Award • Execute investment management agreement • Complete opening documentation • Establish or review custodial relationship • Determine sources of funding Strategy Development • Review Investment Policy • Analyze cash needs • Discuss investment objectives • Assess risk parameters • Create customized investment strategy • Draft management directive Preparing to Invest • Develop funding strategy • Set up read-only access to custodial account • Build assets in Chandler trading and accounting systems • Assign Chandler Client Portal credentials and conduct Portal demonstration • Review Chandler reporting solution with staff • Establish trading rules with Chandler Compliance Team Investment of Funds • Execute funding strategy for initial purchases • Carry out active investment to maintain target portfolio structure • Inform staff on investment progress through regular communication and formal portfolio reviews 7.2 Describe the firm's approach to managing relationships with the broker/dealer community. The Investment Management Team maintains an active, productive relationship with the broker/dealer community in order to promote an ongoing flow of market information and execute trades for our clients at competitive prices. On a given day, various factors may combine to generate the best price for a given transaction, including current dealer inventories, dealer profit/loss positions, and individual dealer 36Page CMCHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO sentiments about the market. No one dealer will consistently provide the best execution. For that reason, we consistently place several dealers in competition and continuously monitor and compare inventories and prices. Given that all of our transactions are executed using "delivery -versus -payment" (DVP) procedures, the firm's broker/dealer selection and retention process center primarily on transactional risk. Thus, our internal criteria for reviewing and monitoring brokers/dealers for approval and retention include: • Competitive pricing • Trade execution efficiency • Consistency of coverage • Quality and breadth of product inventory • Willingness to make a two-way market We monitor financial news for any indication of financial weakness or diminishing participation in our markets. In addition, we are concerned with broker/dealer integrity and capitalization. The Financial Industry Regulatory Authority (FINRA) provides an online BrokerCheck System, which we use to review the credentials and regulatory background of each broker/dealer firm and the employees with whom we trade. 7.3 Describe any assistance the firm would provide in reviewing custodial and safekeeping arrangements. As part of our services, we are able to assist you in reviewing custodial and safekeeping arrangements. Our Operations Team will review your current custodial arrangement, including contractual arrangement, services provided, your satisfaction with the services, and their cost. If necessary, we can make recommendations for revisions in your existing relationship or assist you in selecting a new custodian that best meets your needs. • If the County currently has a satisfactory third -party custodian, we will provide a sample letter for you to send to the custodian which describes the relationship between Chandler and the County, and gives us permission to settle trades with your custodian on your behalf, or; • If the County would like to review custodian relationships, Chandler can recommend several that can provide high -quality custody services and/or participate with the County in an RFP process. 7.4 Describe any other services that the firm believes may be of value to the county. Chandler can provide additional services that will add value to the County's investment program including: • Strategy development or customization of strategies suitable to the County's investment program, • Other Post -Employment Benefit ("OPEB)" Management. Chandler has been managing post - employee benefit accounts such as pension trusts and medical benefit trusts for clients since 2003. We use a multi -asset class strategy (Chandler's "MAC" Strategy) to achieve the objectives and target return of the plan; • Management of the County's cash in strategies including short-term securities as an alternative to LGIPs/other overnight investment pools; • Targeted educational sessions on fixed income and financial topics and issuance of Continuing Professional Education (CPE) credits; • Management of bond reserves and/or bond proceeds; 37 1 i g e CHANDLER ASSET MANAGEMENT Request for Proposals (62200146) for Investment Advisor Services WELD COUNTY, COLORADO z, r re. .t.s-M w ..-+e F _ s y k n nw r ,. • ..r .o^ r- n s. vn_R -r r b. s a • Custodial bank/safekeeping review and selection, and, e Broker/dealer selection and monitoring We look forward to discussing the full suite of service offerings Chandler can provide as investment adviser 7 5 Describe the aspects of your firm that distinguish it from competitors. Chandler distinguishes itself from its competition in several ways, and in all aspects of the relationship with its clients, not limited to its investment management capabilities > Direct contact with investment team Clients have frequent, direct contact with portfolio strategists, senior investment professionals, and the backup investment management team who are responsible for making the decisions for their portfolio You will speak directly and meet frequently with a senior member of the firm, and not with dual -role representatives or intermediaries Your portfolio strategists will not only have a deep understanding of your investment portfolio but also of where it fits in the overall program and its future objectives ➢ Chandler is a "right -size" investment adviser and is uniquely positioned for growth With ten investment professionals, Chandler's portfolio team rivals those of larger firms, however, our niche investment expertise and "boutique" size allow our investment professionals to interface directly with our clients Service and attention to detail is prioritized as second only to the consistent results we offer our clients Our Portfolio managers manage an average of 21 relationships compared to our peers who may manage 90-100 accounts > Chandler delivers consistent, stable, risk -adjusted returns over many market cycles across all possible investing environments Chandler's investment process focuses on risk management through tightly controlled duration, sector allocation, term structure, and security selection to differentiate our performance from that of our peer group Our repeatable, disciplined investment process helps us identify when to alter our asset allocation to be either more or less conservative and to identify an optimal term structure based on the current shape of the yield curve ➢ Deep history and experience. Since 1988, Chandler Asset Management has assisted public agency clients fulfill their fiduciary duty to their constituents by providing high quality fixed income portfolios in a risk -averse framework that conform to all state laws and directives The depth of our experience, expertise and consistent, repeatable investment process is evident in the performance of the investment strategies we have managed for over 20 years We are immensely proud of our 97% five-year client retention statistic, which we attribute to our belief that "if we do what is right for our clients, our own success will follow" ➢ Resources. Chandler's clients count on our extensive research and analytical capabilities used to identify opportunities and minimize risk Our access to market information in conjunction with our proprietary credit review process makes our services of significant value Additionally, our independent compliance team will ensure that all trades conform to Colorado Revised Statutes, the County investment policy, and the customized investment strategy that we will co -develop with the County's staff ➢ Commitment to client success. We are dedicated to our role as fiduciaries to our clients and strive to ease the responsibility and operational requirements needed to effectively invest the County's 38 IPage CA ta \ CHANDLER ASSET MANAGEMENT Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO assets Our comprehensive services provide transparency, excellent client service, and successful investment program outcomes We commit the full resources of the firm to ensure your success 39IPage Chandler Asset Management •. yW % "trt «\y •A- % w -44.71/( Required Forms acA Signature F rm The undersigned, by his or her signature, hereby acknowledges and represents that: 1. The proposal proposed herein meets all of the conditions, specifications and special provisions set forth in the Request for Proposal for Request No. #B2200146. 2. The quotations set forth herein are exclusive of any federal excise taxes and all other state and local taxes 3. He or she is authorized to bind the below -named Vendor for the amount shown on the accompanying proposal sheets. 4. The signed proposal submitted, all of the documents of the Request for Proposal contained herein (including, but not limited to, product specifications and scope of services), and the formal acceptance of the proposal by Weld County, together constitutes a contract, with the contract date being the date of formal acceptance of the proposal by Weld County. 5. Weld County reserves the right to reject any and all proposals, to waive any informality in the proposals, and to accept the proposal that in the opinion of the Board of County Commissioners, is in the best interest of Weld County. The proposal(s) may be awarded to more than one vendor. FIRM Chandler Asset Management BY Nicole Dragoo, JD, IACCP, President (Please print) BUSINESS ADDRESS 6225 Lusk Boulevard CITY, STATE, San Diego, CA 92121 DATE October 17, 2022 ZIP CODE TELEPHONE NO 800-317-4747 SIGNATURE FAX 858-546-3741 TAX ID # 33-0570869 E-MAIL ndragoo@chandlerasset.com WELD COUNTY IS EXEMPT FROM COLORADO SALES TAXES. THE CERTIFICATE OF EXEMPTION NUMBER IS #98-03551-0000. ATTEST: Weld County Clerk to the Board BY: YOU DO NOT NEED TO SEND BACK PAGES 1 - 8. BOARD OF COUNTY COMMISSIONERS WELD COUNTY, COLORADO Deputy Clerk to the Board Scott K. James, Chair APPROVED AS TO SUBSTANCE: Elected Official or Department Head Controller PSRFP0922 PROPOSAL REQUEST #B2200146 Page 16 CM Form W-9 (Rev. October 2018) Department of the Treasury tntemaf Revenue Service Request for Taxpayer Identification Number and Certification ► Go to www.irs.gov/FormW9 for instructions and the latest information. Give Form to the requester. Do not send to the IRS. ii 62 a. v S Oe 1 Name (as shown on your income tax return). Name is required on this fine; do not leave this line blank CHANDLER ASSET MANAGEMENT, INC. 2 Business name/sregarded entity name, it different from above Check appropriate box for federal tax classification of the person whose name is entered on line 1. Check only one of the following seven boxes. ❑ Individual/sole proprietor or 0 C Corporation O S Corporation O Pannen;ltip O Trustlestate single -member LLC ❑ Limited liablity company. Enter the tax classification (C=C corporation, S=S corporation, P=Partnership) ► Note: Check the appropriate box in the line above for the tax classification of the single -member owner. Do not cheek LLC if the LLC is cies.. as a single -member LLC that Is disregarded from the owner unless the owner of the LLC is another LLC that is not disregarded from the owner for U.S. federal tax purposes. Otherwise, a single -member LLC that is disregarded from the owner should check the appropriate box for the tax classification of its owner. (] Other (see instructions) ► Address (number. street, and apt or suite no.) See instructions. 6225 LUSK BLVD 6 City, state, and MP code SAN DIEGO, CA 92121 7 List account number(s) here (optional) 4 Exemptions (codas apply only to certain entities, not individuals: see Instructions on page 3): Exempt payee code (If any) Exemption from PATCH reporting code Of any) Fbar•+Macaw* matntainedoutsidedwUS.) Requester's name and address (optional) gial Taxpayer Identification Number (TIN) Enter your TIN in the appropriate box. The TIN provided must match the name given on line 1 to avoid backup withholding. For individuals, this is generally your social security number (SSN). However, for a resident alien, sole proprietor, or disregarded entity, see the instructions for Part 1, Later. For other entities, it Is your employer identification number (BIN). If you do not have a number, see How to get a 77N, later. Note: if the account is in more than one name, see the instructions for line 1. Also see What Name and Number To Give the Requester for guidelines on whose number to enter. Social security num or Employer Modification number 1 3 3 I I 1 I I I Mal Certification Under penalties of perjury, l certify that: 1. The number shown on this form Is my correct taxpayer identification number (or l am waiting fora number to be issued to me); and 2. I am not subject to backup withholding because: (a) i am exempt from backup withholding, or (b)1 have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all ingest or dividends, or (c) the IRS has notified me that I am no longer subject to backup withholding; and 3. I am a U.S. citizen or other U.S. person (defined below); and 4. The FATCA code(s) entered on this form (If any) indicating that l am exempt from FATCA reporting €s correct. Certification instructions. You must cross out item 2 above if you have been notified by the IRS that you are currently subject to backup withholding because you have failed to report all interest and dividends on your tax return. For real estate transactions, item 2 does not apply. For mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions to an individual retirement arrangement (IRA), and generally, payments other than interest and dividends, you are not required to sign the certification, but you must provide your correct TIN. See the instructions for Part iL later. sign I Signatureof Here U.S person ►r General Instructions Section references are to the internal Revenue Code unless otherwise noted. Future developments. For the latest Information about developments related to Form W-9 and its instructions, such as legislation enacted after they were published, go to www.irs.gov/FennWd. Purpose of Form An individual or entity (Form W-9 requester) who is required to file an information return with the IRS must obtain your correct taxpayer identification number (t7N) which may be your social security number (SSN), individual taxpayer identification number (MN), adoption taxpayer identification number (ATIN), or employer identification number (EIN), to report on an information return the amount paid to you, or other amount reportable on an information return. Examples of information returns include, but are not limited to, the following. • Form 1099-INT (interest earned or paid) oars► 06/16/2022 • Form 1099-DIV (dividends, including those from stocks or mutual funds) • Form 1499-MISC (various types of income, prizes, awards, or gross proceeds) • Fonn 1099-a (stock or mutual fund sales and certain other transactions by brokers) • Form 1099-S (proceeds from real estate transactions) • Form 1099-K (merchant card and third party network transactions) • Form 1098 (home mortgage interest), 1098-E (student loan interest), 1098-T (tuition) • Form 1099-C (canceled debt) • Form 1099-A (acquisition or abandonment of secured properly) Use Fort W-9 only if you area U.S. person (including a resident alien), to provide your correct 115. if you do not retum Fomr W-9 to the requester with a 7IN, you might be subject to backup withholding. See What is backup withholding, later. Cat. No. 10231X Fn. W-9 (Rev. 10-2010) Chandler Asset Management Appendices CM Appendix A Form ADV, Parts 1 and 2 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] FORM ADV UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS Primary Business Name: CHANDLER ASSET MANAGEMENT INC CRD Number: 107287 Other -Than -Annual Amendment - All Sections Rev. 10/2021 WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4. Item 1 Identifying Information Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in Item 1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration. A. Your full legal name (if you area sole proprietor, your last, first, and middle names): CHANDLER ASSET MANAGEMENT INC . (1) Name under which you primarily conduct your advisory business, if different from Item 1.A. CHANDLER ASSET MANAGEMENT INC List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business. (2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box r If you check this box, complete a Schedule R for each relying adviser. . If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name change is of r your legal name or r your primary business name: . (1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-44378 (2) If you report to the SEC as an exempt reporting adviser, your SEC file number: (3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers: 'CIK Number 1665018 . (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 107287 If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates. (2) If you have additional CRD Numbers, your additional CRD numbers: No Information Filed Principal Office and Place of Business (1) Address (do not use a P.O. Box): Number and Street 1: 6225 LUSK BOULEVARD City: State: SAN DIEGO California If this address is a private residence, check this box: r Number and Street 2: Country: United States ZIP+4/Postal Code: 92121-2796 Liston Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to the SEC as an exempt reporting adviser, list https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 1/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] the largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal year. (2) Days of week that you normally conduct business at your principal office and place of business: f?. Monday - Friday r Other: Normal business hcurs at this location: 6:00 AM TO 5:00 PM (3) Telephone number at this location: 858.546.3737 (4) Facsimile number at this location, if any: 858.546.3741 (5) What is the total ni-mber of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of your most recently completed fiscal year? Mailing address, if different from your principal office and place of business address: Number and Street 1: Number and Street 2: City: State: Country: ZIP+4/Postal Code: If this address is a private residence, check this box: r . If you area sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.: Number and Street 1: Number and Street 2: City: State: Country: ZIP+4/Postal Code: Yes No . Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, 18 C `: Facebook and LinkedIn)? If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1, of Schedule D. If a website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of the other information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media platforms where you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on publicly available social media platforms. Chief Compliance Officer (1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below. Name: JOSEPH R. KOLINSKY Telephone number: 858.546.3737 Number and Street 1: 6225LUSK BOULEVARD City: SAN DIEGO State: California Other titles, if any: CHIEF COMPLIANCE OFFICER Facsimile number, if any: 858.546.3741 Number and Street 2: Country: United States Electronic mail (e-mail) address, if Chief Compliance Officer has one: JKOLIN SKY@CHAN DLERASSET.COM ZIP+4/Postal Code: 92121-2796 (2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification Number (if any): Name: IRS Employer Identification Number: . Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about this Form ADV, you may provide that information here. Name: Titles: https://crd.finra.org/lad/Content/PrinlHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 2/42 4/12/22, 6:43 PM NICOLE M. DRAGOO Telephone number: 858.546.3737 Number and Street 1: 6225 LUSK BOULEVARD City: SAN DIEGO State: California IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] PRESIDENT Facsimile number, if any: 858.546.3741 Number and Street 2: Country: United States Electronic mail (e-mail) address, if contact person has one: N DRAGOO@CHAN DLERASSET.COM ZIP+4/Postal Code: 92121-2796 Yes No: Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar C` C state law, somewhere other than your principal office and place of business? If "yes," complete Section 1.L. of Schedule D. . Are you registered with a foreign financial regulatory authority? Yes No C t Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory authority. If "yes," complete Section 1.M. of Schedule D. . Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934? O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year? If yes, what is the approximate amount of your assets: • $1 billion to less than $10 billion - $10 billion to less than $50 billion ✓ $50 billion or more Yes No C r. Yes No C G' For purposes of Item 1.0. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total assets shown on the balance sheet for your most recent fiscal year end. Provide your Legal Entity Identifier if you have one: 254900E9B]WINIZ90E91 A /ega/ entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier. SECTION 1.B. Other Business Names No Information Filed SECTION 1.F. Other Offices Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees). Number and Street 1: Number and Street 2: 7250 REDWOOD BOULEVARD SUITE 300 City: NOVATO State: Country: California United States ZIP+4/Postal Code: 94945 https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.espx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 3/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] If this address is a private residence, check this box: r Telephone Number: Facsimile Number, if any: !! 415.798.5586 858.546.3741 If this office location is also required to be registered with FINRA or a state securities authority as a branch office location fora broker -dealer or investment adviser on the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here: How many employees perform investment advisory functions from this office location? Are other business activities conducted at this office location? (check all that apply) r (1) Broker -dealer (registered or unregistered) r (2) Bank (including a separately identifiable department or division of a bank) r (3) Insurance broker or agent r (4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) I-, (5) Registered municipal advisor r (6) Accountant or accounting firm r (7) Lawyer or law firm Describe any other investment -related business activities conducted from this office location: Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are !I registered only with the SEC, or if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees). Number and Street 1: 3445 TELEGRAPH ROAD City: VENTURA Number and Street 2: SUITE 200 State: Country: California United States If this address is a private residence, check this box: r Telephone Number: Facsimile Number, if any: 800-317-4747 858-546-3741 ZIP+4/Postal Code: 93003 • If this office location is also required to be registered with FINRA or a state securities authority as a branch office location fora broker -dealer or investment adviser on the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here: How many employees perform investment advisory functions from this office location? Are other business activities conducted at this office location? (check all that apply) r (1) Broker -dealer (registered or unregistered) r (2) Bank (including a separately identifiable department or division of a bank) r (3) Insurance broker or agent r (4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) r (5) Registered municipal advisor r (6) Accountant or accounting firm r (7) Lawyer or law firm Describe any other investment -related business activities conducted from this office location: https://crd.finra.org/I ad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSecti ons. aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 4/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees). Number and Street 1: Number and Street 2: 2121 N. CALIFORNIA BLVD SUITE 290 City: WALNUT CREEK State: Country: California United States If this address is a private residence, check this box: r Telephone Number: Facsimile Number, if any: 800-317-4747 ZIP+4/Postal Code: 94596 If this office location is also required to be registered with FINRA or a state securities authority as a branch office location fora broker -dealer or investment adviser on the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here: How many employees perform investment advisory functions from this office location? Are other business activities conducted at this office location? (check all that apply) r (1) Broker -dealer (registered or unregistered) r (2) Bank (including a separately identifiable department or division of a bank) r (3) Insurance broker or agent r (4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) r (5) Registered municipal advisor r (6) Accountant or accounting firm r (7) Lawyer or law firm Describe any other investment -related business activities conducted from this office location: Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees). Number and Street 1: 1875 LAWRENCE STREET City: DENVER Number and Street 2: SUITE 920 State: Country: Colorado United States If this address is a private residence, check this box: r Telephone Number: Facsimile Number, if any: 800.317.4747 303.295.0513 ZIP+4/Postal Code: 80202 If this office location is also required to be registered with FINRA or a state securities authority as a branch office location fora broker -dealer or investment adviser on the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here: How many employees perform investment advisory functions from this office location? https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 5/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Are other business activities conducted at this office location? (check all that apply) r (1) Broker -dealer (registered or unregistered) ! r (2) Bank (including a separately identifiable department or division of a bank) r (3) Insurance broker or agent r (4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) r (5) Registered municipal advisor r (6) Accountant or accounting firm r (7) Lawyer or law firm H Describe any other investment -related business activities conducted from this office location: Number and Street 1: 801 INTERNATIONAL PARKWAY City: 3 LAKE MARY Number and Street 2: SUITE 500 State: Country: Florida United States If this address is a private residence, check this box: r Telephone Number: Facsimile Number, if any: 407-739-8797 Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees). ZIP+4/Postal Code: 32746 If this office location is also required to be registered with FINRA or a state securities authority as a branch office location fora broker -dealer or investment adviser on the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here: How many employees perform investment advisory functions from this office location? Are other business activities conducted at this office location? (check all that apply) r (1) Broker -dealer (registered or unregistered) r (2) Bank (including a separately identifiable department or division of a bank) r (3) Insurance broker or agent r (4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) r (5) Registered municipal advisor r (6) Accountant or accounting firm r (7) Lawyer or law firm Describe any other investment -related business activities conducted from this office location: Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must complete a separate Schedule D Section 1.E for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees). Number and Street 1: 701 5TH AVENUE City: SEATTLE State: Washington Number and Street 2: SUITE 4200 Country: United States ZIP+4/Postal Code: 98104 https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_ied_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 6/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] If this address is a private residence, check this box: r Telephone Number: Facsimile Number, if any: 206-388-5760 206-489-5611 If this office location is also required to be registered with FINRA or a state securities authority as a branch office location fora broker -dealer or investment adviser on the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here: How many employees perform investment advisory functions from this office location? Are other business activities conducted at this office location? (check all that apply) r (1) Broker -dealer (registered or unregistered) r (2) Bank (including a separately identifiable department or division of a bank) r (3) Insurance broker or agent r (4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) r (5) Registered municipal advisor I— (6) Accountant or accounting firm r (7) Lawyer or law firm Describe any other investment -related business activities conducted from this office location: SECTION 1.I. Website Addresses List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited to, Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media platform. Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.CHANDLERASSET.COM Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/911143/ Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/channel/UCIUGGxVg75mCArkBSkyWRRw SECTION 1.L. Location of Books and Records Complete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must complete a separate Schedule D, Section 1.L. for each location. Name of entity where books and records are kept: CORODATA Number and Street 1: 12370 KERRAN STREET City: POWAY State: California If this address is a private residence, check this box: r Number and Street 2: Country: United States Telephone Number: Facsimile number, if any: 858.748.7202 858.748.9506 ZIP-F4/Postal Code: 92064 https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 7/42 4/12/22, 6:43 PM This is (check one): C one of your branch offices or affiliates. 6. a third -party unaffiliated recordkeeper. C other. IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Briefly describe the books and records kept at this location. BROKERAGE CONFIRMS OLDER THAN 2 YEARS, CLIENT STATEMENTS, CLOSED ACCOUNT FILES, AND ARCHIVED ACCOUNTS PAYABLE RECORDS. Name of entity where books and records are kept: SALESFORCE Number and Street 1: 415 MISSION STREET City: SAN FRANCISCO !lumber and Street 2: 3RD FLOOR State: Country: California United States If this address is a private residence, check this box: r Telephone Number: Facsimile number, if any: 8006676389 This is (check one): C one of your branch offices or affiliates. a a third -party unaffiliated recordkeeper. C other. Briefly describe the books and records kept at this location. CLIENT, VENDORS, AND PROSPECTS CONTACT DATA & CORRESPONDING CLIENT SERVICES DATA Name of entity where books and records are kept: SCHWAB COMPLIANCE TECHOLOGIES Number and Street 1: 150 SOUTH WACKER DRIVE City: CHICAGO State: Illinois If this address is a private residence, check this box: r Telephone Number: 877-553-1961 This is (check one): r one of your branch offices or affiliates. 51 a third -party unaffiliated recordkeeper. C other. Number and Street 2: SUITE 200 Country: United States Facsimile number, if any: Briefly describe the books and records kept at this location. COMPLIANCE DOCUMENTATION AND OUR COMPLIANCE CALENDAR ZIP+4/Postal Code: 94105 ZIP+4/Postal Code: 60606 https://crd.finra.org/lad/Content/PrintH ist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefN um=9175437628190CF5&viewChanges=&FLN G_PK= 8/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Name of entity where books and records are kept: ROCKETDOCS Number and Street 1: Number and Street 2: 509 SOUTH EXETER STREET SUITE 306 City: BALTIMORE State: Country: Maryland United States If this address is a private residence, check this box: r Telephone Number: Facsimile number, if any: 4104031189 This is (check one): r one of your branch offices or affiliates. 6 a third -party unaffiliated recordkeeper. r other. Briefly describe the books and records kept at this location. RFP AND PROPOSAL DATA Name of entity where books and records are kept: SMARSH Number and Street 1: 110 WILLIAM STREET City: NEW YORK State: New York If this address is a private residence, check this box: r Telephone Number: 866-762-7741 This is (check one): r one of your branch offices or affiliates. a third -party unaffiliated recordkeeper. r other. Number and Street 2: SUITE 1804 Country: United States Facsimile number, if any: Briefly describe the books and records kept at this location. EMAIL ARCHIVING SECTION 1.M. Registration with Foreign Financial Regulatory Authorities No Information Filed ZIP+4/Postal Code: 21202 ZIP+4/Postal Code: 10038 hops://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 9/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Item 2 SEC Registration/Reporting Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC registration or submitting an annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided for the filing adviser only. I To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help you determine whether you may affirmatively respond to each of these items. You (the adviser): F7 (1) area large advisory firm that either: (a) has regulatory assets under management of $100 million (in U.S. dollars) or more; or (b) has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and is registered with the SEC; are a mid -sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and you are either: (a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business; or (b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business; r (2) Click HERE fora list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority. (3) Reserved r (4) have your principal office and place of business outside the United States; ✓ (5) are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940; r (6) are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under management; ✓ (7) area pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A -2(a); r (8) area related adviser under rule 2030-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, and your principal office and place of business is the same as the registered adviser; If you check this box, complete Section 2.0.(8) of Schedule D. r (9) are an adviser relying on rule 203A -2(c) because you expect to be eligible for SEC registration within 120 days; If you check this box, complete Section 2.A.(9) of Schedule D. r (10) area multi -state adviser that is required to register in 15 or more states and is relying on rule 2030-2(d); If you check this box, complete Section 2.0.(10) of Schedule D. r (11) are an Internet adviser relying on rule 203O -2(e); r (12) have received an SEC order exempting you from the prohibition against registration with the SEC; If you check this box, complete Section 2.A.(12) of Schedule D. r (13) are no longer eligible to remain registered with the SEC. State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers C. Under state laws, SEC -registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck the box(es) next to those state(s). https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 10/42 4/12/22, 6:43 PM Jurisdictions W. AL F AK FAZ W. AR W. CA F CO W. CT W. DE r DC P7 FL F GA r GU W HI W ID F IL W IN r IA W KS r KY W. LA W ME W MD W MA W MI W MN r ms r MO r MT IARD - All Sections [User Name: jkolinsky2, 0rgID: 107287] W NE P" sc r NV r SD P- NH FTN P" NJ FTX FNM r7 UT W NY r VT r NC r VI ["ND FVA 17 OH r WA 17 OK P- WV F OR P..' F7 PA r WY r PR F RI If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31). SECTION 2.A.(8) Related Adviser If you are relying on the exemption in rule 203A -2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following information: Name of Registered Investment Adviser CRD Number of Registered Investment Adviser SEC Number of Registered Investment Adviser SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 Days If you are relying on rule 203A -2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within 120 days, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations. You must make both of these representations: r I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register with the SEC within 120 days after the date my registration with the SEC becomes effective. r I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a) of the Advisers Act from registering with the SEC. SECTION 2.A.(10) Multi -State Adviser If you are relying on rule 203A -2(d), the multi -state adviser exemption from the prohibition on registration, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations. If you are applying for registration as an investment adviser with the SEC, you must make both of these representations: r I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser with the state securities authorities in those states. r I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to register as an investment adviser with the state securities authorities of those states. If you are submitting your annual updating amendment, you must make this representation: r https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAilSections.aspx?RefNum=9175437628190CF58,viewChanges=&FLNG_PK= 11/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of at least 15 states to register as an investment adviser with the state securities authorities in those states. SECTION 2.A.(12) SEC Exemptive Order If you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information: Application Number: 803 - Date of order: https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 12/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Item 3 Form of Organization If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only. A. How are you organized? t: Corporation ✓ Sole Proprietorship ✓ Limited Liability Partnership (LLP) ✓ Partnership ✓ Limited Liability Company (LLC) f. Limited Partnership (LP) ✓ Other (specify): If you are changing your response to this Item, see Part IA Instruction 4. . In what month does your fiscal year end each year? DECEMBER C. Under the laws of what state or country are you organized? State Country California United States If you area partnership, provide the name of the state or country under whose laws your partnership was formed. If you area sole proprietor, provide the name of the state or country where you reside. If you are changing your response to this Item, see Part IA Instruction 4. https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 13/42 4/12/22, 6:43 PM Item 4 Successions IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Yes No Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or legal status (e.g., form of organization or state of incorporation)? If "yes", complete Item 4.B. and Section 4 of Schedule D. . Date of Succession: (MM/DD/YYYY) If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4. SECTION 4 Successions No Information Filed https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 14/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Item 5 Information About Your Advisory Business - Employees, Clients, and Compensation Responses to this Item help us understand your business, assist us in preparing for on -site examinations, and provide us with data we use when making regulatory policy. Part 12 Instruction 5.a. provides additional guidance to newly formed advisers for completing this Item 5. Employees If you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.8.(1), (2), (3), (4), and (5). If an employee performs more than one function, you should count that employee in each of your responses to Items 5.8.(1), (2), (3), (4), and (5). A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers. 37 B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)? 16 (2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker -dealer? (3) (4) (5) (6) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives? 16 Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for an investment adviser other than you? Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency? Approximately how many firms or other persons solicit advisory clients on your behalf? In your response to Item 5.8.(6), do not count any of your employees and count a firm only once - do not count each of the firm's employees that solicit on your behalf. Clients In your responses to Items S.C. and 5.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. C. (1) To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during your most recently completed fiscal year? (2) Approximately what percentage of your clients are non -United States persons? For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not include businesses organized as sole proprietorships. The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940. Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do not answer (1)(d) or (3)(d) below. Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond to Item 5.D.(1(. The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management reported in Item 5.F.(2)(c) below. If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as applicable. https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 15/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Type of Client (1) Number of Client(s) (2) Fewer than 5 Clients (3) Amount of Regulatory Assets under Management (a) Individuals (other than high net worth individuals) 488 r $ 258,776,307 (b) High net worth individuals 190 r $ 130,594,110 (c) Banking or thrift institutions 1 P $ 560,291 (d) Investment companies 0 $ 0 (e) Business development companies 0 $ 0 (f) Pooled investment vehicles (other than investment companies and business development companies) 0 $ 0 (g) Pension and profit sharing plans (but not the plan participants or government pension plans) 2 r $ 16,942,771 (h) Charitable organizations 17 r $ 153,925,425 (i) State or municipal government entities (including government pension plans) 176 r $ 20,821,151,657 (j) Other investment advisers 0 r $ 0 (k) Insurance companies 0 r $ 0 (I) Sovereign wealth funds and foreign official institutions 0 r $ 0 (m) Corporations or other businesses not listed above 14 r $ 53,012,046 (n) Other: HOSPITALS 9 r $ 4,350,011,360 Compensation Arrangements E. You are compensated for your investment advisory services by (check all that apply): P- (1) A percentage of assets under your management FT (2) Hourly charges ✓ (3) Subscription fees (fora newsletter or periodical) FT (4) Fixed fees (other than subscription fees) r (5) Commissions ✓ (6) Performance -based fees ✓ (7) Other (specify): Item 5 Information About Your Advisory Business - Regulatory Assets Regulatory Assets Under Management Yes No A C` F. (1) Do you provide continuous and regular supervisory or management services to securities portfolios? (2) If yes, what is the amount of your regulatory assets under management and total number of accounts? Discretionary: Non -Discretionary: Total: U.S. Dollar Amount (a) $ 21,726,632,304 (b) $ 4,058,341,663 (c) $ 25,784,973,967 Total Number of Accounts (d) 1,048 (e) 74 (f) 1,122 Part IA Instruction 5.b. explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this Item. (3) What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are non -United States persons? $0 Item 5 Information About Your Advisory Business - Advisory Activities Advisory Activities G. What type(s) of advisory services do you provide? Check all that apply. ✓ (1) Financial planning services P- (2) Portfolio management for individuals and/or small businesses ✓ (3) Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of the Investment Company Act of 1940) ✓ (4) Portfolio management for pooled investment vehicles (other than investment companies) ✓ https://crd.finra.org/lad/Content/PrintHlst/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 16/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 1072871 (5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles) ✓ (6) Pension consulting services ✓ (7) Selection of other advisers (including private fund managers) ✓ (8) Publication of periodicals or newsletters ✓ (9) Security ratings or pricing services r (10) Market timing services ✓ (11) Educational seminars/workshops ✓ (12) Other(specify): CONSULTING Do not check Item 5.0.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment companies to which you provide advice in Section 5.G.(3) of Schedule D. If you provide financial planning services, to how many clients did you provide these services during your last fiscal year? • 0 • 1-10 ✓ 11-25 ✓ 26 - 50 ✓ 51 - 100 ✓ 101 - 250 r 251 - 500 ✓ More than 500 If more than 500, how many? (round to the nearest 500) In your responses to this Item 5.H., do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those investors. Yes No (1) Do you participate in a wrap fee program? o_ (2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as: (a) sponsor to a wrap fee program $0 (b) portfolio manager for a wrap fee program? $ 173,592,459 (c) sponsor to and portfolio manager for the same wrap fee program? $0 If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.7.(2)(b). If you area portfolio manager fora wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D. If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee program, do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2). (1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments? (2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets under management? . Separately Managed Account Clients (1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients)? If yes, complete Section 5.K.(1) of Schedule D. https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 17/42 Yes No A r r Yes No r r 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] (2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise? If yes, complete Section. 5.K. (2) of Schedule D. (3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise? If yes, complete Section 5.K. (2) of Schedule D. C c: C /8 (4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any t; C custodian hold ten percent or more of this remaining amount of regulatory assets under management? If yes, complete Section 5.K.(3) of Schedule D for each custodian. Marketing Activities (1) Do any of your advertisements include: (a) Performance results? (b) A reference to specific investment advice provided by you (as that phrase is used in rule 206(4)-1(a)(5))? (c) Testimonials (othe- than those that satisfy rule 206(4)-1(b)(4)(ii))? (d) Endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii))? (e) Third -party ratings? (2) If you answer "yes" to L(1)(c), (d), or (e) above, do you pay or otherwise provide cash or non -cash compensation, directly or indirectly, in connection with the use of testimonials, endorsements, or third -party ratings? (3) Do any of your advertisements include hypothetical performance ? (4) Do any of your advertisements include predecessor performance ? SECTION 5.5.(3) Advisers to Registered Investment Companies and Business Development Companies No Information Filed SECTION 5.I.(2) Wrap Fee Programs Yes No C. C C C. C A C A C C C C C• C C A If you area portfolio manager for one or more wrap fee programs, list the name of each program and its sponsor. You must complete a separate Schedule D Section 5.I.(2) for each wrap fee program for which you area portfolio manager. Name of Wrap Fee Program MANAGED ACCOUNTS SELECT Name of Sponsor CHARLES SCHWAB & CO., INC. Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-): 801 - 29938 Sponsor's CRD Number (if any): 5393 https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF58a/iewChanges=&FLNG_PK= 18/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Name of Wrap Fee Program SEPARATELY MANAGED ACCOUNTS (SMA) PROGRAM Name of Sponsor ENVESTNET PMC Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-): 801 - 57260 801 - 57260 Sponsor's CRD Number (if any): 111694 SECTION 5.K.(1) Separately Managed Accounts After subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this remaining amount attributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management, complete Question (a). If the remaining amount is less than $10 billion in regulatory assets under management, complete Question (b). Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. If you area subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid -year is the date six months before the end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent. Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those categories. Do not report those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers' acceptances and similar bank instruments. Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and the conventions of your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and consistent with information you report internally and to current and prospective clients. However, you should not double count assets, and your responses must be consistent with any instructions or other guidance relating to this Section. (a) Asset Type Mid -year End of year (i) Exchange Traded Equity Securities 0 % 0 (ii) Non Exchange -Traded Equity Securities 0 % 0 (iii) U.S. Government/Agency Bonds 57 % 57 (iv) U.S. State and Local Bonds 0 % 0 https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 19/42 4/12/22, 6:43 PM (v) Sovereign Bonds IARD - All Sections [User Name: jkolinsky2, OrgID: 1072871 0 (b) (vi) Investment Grade Corporate Bonds 18 % 19 (vii) Non -Investment Grade Corporate Bonds 1 % 1 0/0 (viii) Derivatives 0 % 0 % (ix) Securities Issued by Registered Investment Companies or Business Development Companies 11 % 11 0/0 (x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies) 1 % 1 (xi) Cash and Cash Equivalents 5 % 4 (xii) Other 7 % 8 % Generally describe any assets included in "Other" MORTGAGE -BACKED SECURITIES (MBS), ASSET -BACKED SECURITIES (ABS), COLLATERALIZED MORTGAGE OBLIGATIONS (CMOS) AND SUPRANATIONALS Asset Type End of year (i) Exchange -Traded Equity Securities 0/0 (ii) Non Exchange -Traded Equity Securities (Hi) U.S. Government/Agency Bonds (iv) U.S. State and Local Bonds 0/0 (v) Sovereign Bonds (vi) Investment Grade Corporate Bonds 0/0 (vii) Non -Investment Grade Corporate Bonds (viii) Derivatives 0/0 (ix) Securities Issued by Registered Investment Companies or Business Development Companies 0/0 (x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies) (xi) Cash and Cash Equivalents (xii) Other 0/0 Generally describe any assets included in "Other" SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand Derivatives r No information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.0.(2) If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your regulatory assets under management attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question (b). (a) In the table below, provice the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment. Mid -year is the date six months before the end of year date. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in column 1 with respect to each category of derivatives specified in 3(a) through (f). https://crd.finra.org/lad/Content/PrintHlst/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 20/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. (i) Mid -Year Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings (3) Derivative Exposures (a) Interest Rate Derivative (b) Foreign Exchange Derivative (6) Credit Derivative (d) Equity Derivative (e) Commodity Derivative (f) Other Derivative Less than 10% $ $ % % ')/0 % % % 10-149% $ $ % % % % % 150% or more $ $ Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. (ii) End of Year Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings (3) Derivative Exposures (a) Interest Rate Derivative (b) Foreign Exchange Derivative (6) Credit Derivative (d) Equity Derivative (e) Commodity Derivative (f) Other Derivative Less than 10% $ $ % % % % % 10-149% $ $ 150% or more $ $ Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. (b) In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory assets under management for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise. In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account. In column 2, provide the dollar amount of borrowings for the accounts included in column 1. You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than $10,000,000. Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below. Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings Less than 10% $ $ 10-149% $ $ 150% or more $ $ https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_ied_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 21/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the management of the separately managed accounts that you advise. SECTION 5.K.(3) Custodians for Separately Managed Accounts Complete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets under management. (a) Legal name of custodian: THE BANK OF NEW YORK MELLON CORPORATION (b) Primary business name of custodian: BNY MELLON (c) The location(s) of the custodian's office(s) responsible for custody of the assets : City: State: JACKSONVILLE Florida (d) Is the custodian a related person of your firm? (e) If the custodian is a broker -dealer, provide its SEC registration number (if any) Country: United States Yes No (f) If the custodian is not a broker -dealer or is a broker -dealer but does not have an SEC registration number, provide its legal entity identifier (if any) WFLLPEPC7FZXENRZV188 (g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian? $ 5,271,539,996 (a) Legal name of custodian: WELLS FARGO BANK N.A.0 (b) Primary business name of custodian: WELLS FARGO (c) The location(s) of the custodian's office(s) responsible for custody of the assets City: State: MINNEAPOLIS Minnesota (d) Is the custodian a related person of your firm? (e) If the custodian is a broker -dealer, provide its SEC registration number (if any) Country: United States r r. Yes No (f) If the custodian is not a broker -dealer, or is a broker -dealer but does not have an SEC registration number, provide its legal entity identifier (if any) PBLDOEJDB5FWOLXP3B76 (g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian? $ 6,729,059,045 (a) Legal name of custodian: U.S. BANK, NA (b) Primary business name of custodian: US BANK, NA (c) The location(s) of the custodian's office(s) responsible for custody of the assets : City: State: Country: CINCINNATI Ohio United States https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 22/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Yes No (d) Is the custodian a related person of your firm? (e) If the custodian is a broker -dealer, provide its SEC registration number (if any) (f) If the custodian is not a broker -dealer, or is a broker -dealer but does not have an SEC registration number, provide its legal entity identifier (if any) 6BYL5WYBDK8S7L73M02 (g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian? $ 10,685,111,817 C to https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 23/42 4/12/22, 6:43 PM ,Item 6 Other Business Activities In this Item, we request information about your firm's other business activities. You are actively engaged in business as a (check all that apply): ✓ (1) broker -dealer (registered or unregistered) ✓ (2) registered representative of a broker -dealer ✓ (3) commodity pool operator or commodity trading advisor (whether registered or exempt from registration) ✓ (4) futures commission merchant ✓ (5) real estate broker, dealer, or agent ✓ (6) insurance broker or agent ✓ (7) bank (including a separately identifiable department or division of a bank) ✓ (8) trust company ✓ (9) registered municipal advisor ✓ (10) registered security -based swap dealer ✓ (11) major security -based swap participant ✓ (12) accountant or accounting firm r (13) lawyer or law firm r (14) other financial product salesperson (specify): IARD - All Sections [User Name: jkolinsky2, OrgID: 107287) If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.8.(1), complete Section 6.A. of Schedule D. . (1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)? (2) If yes, is this other business your primary business? Yes No / C If "yes," describe this other business on Section 6.8. (2) of Schedule D, and if you engage in this business under a different name, provide that name. (3) Do you sell products or provide services other than investment advice to your advisory clients? Yes No r If "yes," describe this other business on Section 6.8. (3) of Schedule D, and if you engage in this business under a different name, provide that name. SECTION 6.A. Names of Your Other Businesses No Information Filed r SECTION 6.B.(2) Description of Primary Business Describe your primary business (not your investment advisory business): If you engage in that business under a different name, provide that name: SECTION 6.B.(3) Description of Other Products and Services Describe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above. If you engage in that business under a different name, provide that name: https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 24/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Item 7 Financial Industry Affiliations In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur between you and your clients. A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory affiliates and any person that is under common control with you. You have a related person that is a (check Ml that apply): r r r r r r r r r r r r r r r r (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) accountant or accounting firm (11) lawyer or law firm (12) insurance company or agency (13) pension consultant (14) real estate broker or dealer (15) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles (16) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles broker -dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered) other investment adviser (including financial planners) registered municipal advisor registered security -based swap dealer major security -based swap participant commodity pool operator or commodity trading advisor (whether registered or exempt from registration) futures commission merchant banking or thrift institution trust company Note that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker -dealer. The number of your firm's employees who perform investment advisory functions should be disclosed under Item 5.1.(1). The number of your firm's employees who are registered representatives of a broker -dealer should be disclosed under Item 5.11(2). Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A. in Schedule D for your relying advisers. You should complete a Schedule R for each relying adviser. For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D. You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you haven() reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients. You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other than any mutual fund transfer agent pursuant to rule 206(4)-2(6)(1)), regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act. Item 7 rid Reporting B. Are you an adviser to any private fund? Yes No r C ti If "yes," then for each private fund that you advise, you must complete a Section 7.11(1) of Schedule D, except in certain circumstances described in the next sentence and in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another SEC -registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.'1(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.8.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.8.(2) of Schedule D. In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.8. (1) or https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 25/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] 7.B.(2) of Schedule D using the same code or designation in place of the fund's name. SECTION 7.B.(1) Private Fund Reporting 'SECTION 7.B.(2) Private Fund Reporting No Information Filed No Information Filed https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 26/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Item 8 Participation or Interest in Client Transactions In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of interest may occur between you and your clients. Newly -formed advisers should base responses to these questions on the types of participation and interest that you expect to engage in during the next year. Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates. Proprietary Interest in Client Transactions A. Do you or any related person: (1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)? (2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients? (3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (other than those mentioned in Items 8.A.(1) or (2))? Sales Interest in Client Transactions Do you or any related person: (1) as a broker -dealer or registered representative of a broker -dealer, execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions)? (2) recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or any related person serves as underwriter or general or managing partner? (3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of sales commissions as a broker or registered representative of a broker -dealer)? Investment or Brokerage Discretion C. Do you or any related person have discretionary authority to determine the: (1) securities to be bought or sold fora client's account? (2) amount of securities to be bought or sold for a client's account? (3) broker or dealer to be used fora purchase or sale of securities fora client, account? (4) commission rates to be paid to a broker or dealer fora client's securities transactions? . If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons? . Do you or any related person recommend brokers or dealers to clients? F. If you answer "yes" to E. above, are any of the brokers or dealers related persons? Yes No C a C C C a Yes No C a C to ✓ f� Yes No C•` C a C C` C a C C r. • C C C . (1) Do you or any related person receive research or other products or services other than execution from a broker -dealer or a C third party ("soft dollar benefits") in connection with client securities transactions? (2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage C C services" under section 28(e) of the Securities Exchange Act of 1934? H. (1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals? C f; (2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to f; r obtaining clients for the firm (cash or non -cash compensation in addition to the employee's regular salary)? Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person) for client referrals? In your response to Item B.I., do not include the regular salary you pay to an employee. C c: In responding to Items S.H. and B.I., consider all cash and non -cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in answering Item 8.1.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals. https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF58MewChanges=&FLNG_PK= 27/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Item 9 Custody In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment Company Act of 1940) assets and about your custodial practices. . (1) Do you have custody of any advisory clients': (a) cash or bank accounts? (b) securities? Yes No C C ' C If you are registering or registered with the SEC, answer "No" to Item 9.A.(d)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from your clients' accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person. (2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have custody: U.S. Dollar Amount Total Number of Clients If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from you clients' accounts, do not include the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that information in your response to Item 9.11(2). . (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients': (a) cash or bank accounts? (b) securities? You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b). Yes No C a C a (2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related persons have custody: U.S. Dollar Amount Total Number of Clients (a) $ (b) If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that apply: (1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) r you manage. (2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to the investors in the pools. (3) An independent public accountant conducts an annual surprise examination of client funds and securities. (4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodians for client funds and securities. r r r If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the auditor examination or prepare an internal control report. If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect to the private funds you advise in Section 7.8. (1) of Schedule O). Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide to Yes No clients? (1) you act as a qualified custodian (2) your related person(s) act as qualified custodian(s) f �. If you checked "yes" to Item 9.D.(2), a// related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)) must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of the Advisers Act. https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF58,viewChanges=&FLNG_PK= 28/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] . If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year, provide the date (MM/YYYY) the examination commenced: If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as qualified custodians for your clients in connection with advisory services you provide to clients? 22 SECTION 9.C. Independent Public Accountant No Information Filed https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_lad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 29/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Item 10 Control Persons In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information A Item 10 should be provided for the filing adviser only. If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C. Yes No A. Does any person not named A Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies? If yes, complete Section 10.A. of Schedule D. . If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934, please complete Section 10.6. of Schedule D. SECTION 10.A. Control Persons No Information Filed SECTION 10.B. Control Person Public Reporting Companies No Information Filed https://crd.finra.org/lad/Content/Print'Nist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 30/42 4/12/22, 6:43 PM Item 11 Disclosure Information IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser, and to identify potential problem areas to focus on during our on -site examinations. One event may result in "yes" answers to more than one of the questions below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an umbrella registration. Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you area "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are. If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.4.(2), 11.B.(1), 11.B.(2), 11.1(4), and 11.H.(1)(a). For purposes of calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed. You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11. Do any of the events below involve you or any of your supervised persons? For "yes" answers to the following questions, complete a Criminal Action DRP: A. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony? (2) been charged with any felony? Yes No ✓ C•' Yes No C Op r If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.4. (2) to charges that are currently pending. . In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor r involving: investments or an investment -related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses? (2) been charged with a misdemeanor listed in Item 11.6.(1)? r If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.0.(2) to charges that are currently pending. For "yes" answers to the following questions, complete a Regulatory Action DRP: C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: (1) found you or any advisory affiliate to have made a false statement or omission? (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes? (3) found you or any advisory affiliate to have been a cause of an investment -related business having its authorization to do business denied, suspended, revoked, or restricted? (4) entered an order against you or any advisory affiliate in connection with investment -related activity? (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity? Yes No 0_ t i r ✓ r S, ✓ • i^ . Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: (1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical? r (2) ever found you or any advisory affiliate to have been involved in a violation of investment -related regulations or statutes? (3) ever found you or any advisory affiliate to have been a cause of an investment -related business having its authorization to do business denied, suspended, revoked, or restricted? (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment -related activity? (5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment -related business or restricted your or any advisory affiliate's activity? r ✓ t: is r r i' https://crd.finra. org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSecti ons. aspx?RefNum=9175437628190CF5&viewChanges=&F LNG_PK= 31/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Has any self -regulatory organization or commodities exchange ever: (1) found you or any advisory affiliate to have made a false statement or omission? r A, (2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a r., "minor rule violation" under a plan approved by the SEC)? (3) found you or any advisory affiliate to have been the cause of an investment -related business having its authorization to do business denied, suspended, revoked, or restricted? (4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or 1 f; suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities? Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended? . Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.? For "yes" answers to the following questions, complete a Civil Judicial Action DRP: H. (1) Has any domestic or foreign court: Yes No (a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment -related activity? (b) ever found that you or any advisory affiliate were involved in a violation of investment -related statutes or regulations? -- (c) ever dismissed, pursuant to a settlement agreement, an investment -related civil action brought against you or any f" advisory affiliate by a state or foreign financial regulatory authority? (2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)? C https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 32/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Item 12 Small Businesses The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you meet the definition of "small business" or "small organization" under rule 0-7. Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state registration, or switching from SEC to state registration. For purposes of this Item 12 only: • Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that amount is larger). • Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the profits, of another person is presumed to control the other person. A. Did you have total assets of $5 million or more on the last day of your most recent fiscal year? If "yes," you do not need to answer Items 12.B. and 12.C. Yes No r r B. Do you: (1) control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) r r of Form ADV) of $25 million or more on the last day of its most recent fiscal year? (2) control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most r r recent fiscal year? . Are you: (1) controlled by or under common control with another investment adviser that had regulatory assets under management r (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year? (2) controlled by or under common control with another person (other than a natural person) that had total assets of $5 million r or more on the last day of its most recent fiscal year? https://crd.finra. org/lad/Content/PrintHist/Adv/Secti ons/crd_iad_AdvAllSecti ons. aspx?RefNum=9175437628190CF5&viewChanges=&FLN G_P. 33/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Schedule A Direct Owners and Executive Officers 1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use Schedule C to amend this information. 2. Direct Owners and Executive Officers. List below the names of: (a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions; (b) if you are organized as a corporation, each shareholder that is a direct owner of 5./0 or more of a class of your voting securities, unless you area public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act); Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (o) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security. (0 if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or more of your capital; (d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 50/0 or more of your capital, the trust and each trustee; and (e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of your capital, and (ii) if managed by elected managers, all elected managers. Do you have any indirect owners to be reported on Schedule B? A Yes " No 4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner or executive officer is an individual. 5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued). 6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75% A - 5% but less than 10% C - 25% but less than 50% E - 75% or more 7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons. (b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act. (c) Complete each column. FULL LEGAL NAME (Individuals: Last Name, First Name, Middle Name) DE/FE/I Title or Status Date Title or Status Acquired MM/YYYY Ownership Code Control Person PR CRD No. If None: S.S. No. and Date of Birth, IRS Tax No. or Employer ID No. CASSELL, MARTIN, DAYLE I CEO 01/2008 C Y N 4330905 CHANDLER, MARY, CATHERINE I DIRECTOR 07/1993 NA Y N 2276868 DRAGOO, NICOLE, MARIE I PRESIDENT 04/2021 NA Y N 4263078 SCHMITT, JAYSON I CO -CHIEF INVESTMENT OFFICER 01/2022 NA Y N 4892847 PIORKOWSKI, TED, JAMES I SENIOR PORTFOLIO MANAGER 01/2007 NA N N 1857510 , CHANDLER ASSET MANAGEMENT INC. EMPLOYEE STOCK OWNERSHIP PLAN 8, TRUST DE SHAREHOLDER 07/2017 D Y N 81-2142236 KOLINSKY, JOSEPH, ROBERT I CHIEF COMPLIANCE OFFICER 04/2021 NA N N 2250653 DENNEHY, WILLIAM I CO -CHIEF INVESTMENT OFFICER 01/2022 NA N N 2397527 PRICKETT, SCOTT, DAVID I CO -CHIEF INVESTMENT OFFICER 01/2022 NA N N 1901448 TAUBER, RYAN, EDWARD I MANAGING DIRECTOR OF BUSINESS DEVELOPMENT 07/2020 NA N N 4007762 https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 34/42 4/12/22, 6:43 PM Schedule B Indirect Owners IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] 1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information. 2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below: (a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 25% or more of a class of a voting security of that corporation; For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security. (b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 25./0 or more of the partnership's capital; (c) in the case of an owner that is a trust, the trust and each trustee; and (d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers. 3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the Exchange Act) is reached, no further ownership information need be given. 4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the owner is an individual. 5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued). 6. Ownership codes are: C - 25% but less than 50% E - 75% or more D - 50% but less than 75% F - Other (general partner, trustee, or elected manager) 7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons. (b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act. (c) Complete each column. FULL LEGAL NAME DE/FE/I Entity in Which Interest is Status Date Ownership Control PR CRD No. If (Individuals: Last Name, First Name, Middle Name) Owned Status Acquired Code Person None: S.S. No. and Date of MM/YYYY Birth, IRS Tax No. or Employer ID No. PRUDENT FIDUCIARY DE CHANDLER ASSET ESOP TRUST 10/2021 F N N 82-1818132 SERVICES MANAGEMENT, INC. EMPLOYEE ADMINISTRATOR STOCK OWNERSHIP PLAN & TRUST https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 35/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Schedule D - Miscellaneous You may use the space below to explain a response to an Item or to provide any other information. Chandler's soft dollar policy prohibits us from entering into third party oft dollar arrangements, please see our Part 2A for additional disclosures. On December 3, 2021, Chandler Asset Management's Employee Stock Ownership Plan ("ESOP") closed on its purchase of the remaining interest held in the firm owned by the firm's Founder, Kay Chandler. Asa result of this purchase, the firm's ESOP now owns 68% of Chandler Asset Management Inc. The firm's Chief Executive Officer, Martin Cassell, continues to hold a 25% interest in the firm, and remaining 7% of the company continues to be held by senior level employees. Kay Chandler will continue as a Director on the firm's Board. As the firm has continued to grow, Chandler's Board of Directors made the decision to outsource the responsibility of Trustee of the company's ESOP to an independent third party, Prudent Fiduciary Services ("Prudent"). Prudent's sole responsibility is to oversee the ESOP trust on behalf of Chandler employee participants. Prudent serves at the discretion of the Board of Directors who retains all authority over the day-to-day management of !. the firm. On December 31, 2321, Martin Cassell relinquished his title of Chandler's Chief Investment Officer. He does, however, maintain his title of CEO. Jayson Schmitt, William Dennehy, and Scott Prickett have been promoted from their Deputy CIO positions to Co -Chief Investment Officers of Chandler Asset Management Inc. Chandler has issued a press release pertaining to these promotions, which can be found on Chandler's website, www.chandlerasset.com . https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 36/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Schedule R No Information Filed https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 37/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 1072871 https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 38/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Part2 Exemption from brochure delivery requirements for SEC -registered advisers SEC rules exempt SEC -registered advisers from delivering a firm brochure to some kinds of clients. If these exemptions excuse you from delivering a brochure to a// of your advisory clients, you do not have to prepare a brochure. Are you exempt from delivering a brochure to all of your clients under these rules? If no, complete the ADV Part 2 filing below. yes No r R ! Brochure ID Brochure Name Brochure Type(s) Action 365778 CHANDLER ASSET MANAGEMENT INC. FORM ADV PART 2A AS OF MARCH 2022 Individuals, High net worth individuals, Pension plans/profit sharing plans, Foundations/charities, Government/municipal, Other institutional, Wrap program No Change https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 39/42 4/12/22, 6:43 PM Part IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] CRS b Type(s) Investment Adviser Affiliate Info Retire https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 40/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] Execution Pages DOMESTIC INVESTMENT ADVISER EXECUTION PAGE You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and all amendments. Appointment of Agent for Service of Process By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing. Signature I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act. I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of these books and records to make them available to federal and state regulatory representatives. Signature: MARTIN CASSELL Printed Name: MARTIN CASSELL Adviser CRD Number: 107287 Date: MM/DD/YYYY 04/12/2022 Title: CEO NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC and all amendments. 1. Appointment of Agent for Service of Process By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a notice filing. 2. Appointment and Consent: Effect on Partnerships If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this irrevocable power of attorney and consent shall be in effect for any action brought against you or any of your former partners. 3. Non -Resident Investment Adviser Undertaking Regarding Books and Records By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 41/42 4/12/22, 6:43 PM IARD - All Sections [User Name: jkolinsky2, OrgID: 107287] office in Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission, correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940. This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of attorney or any of your general partners and managing agents. Signature I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act. I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or possession of these books and records to make them available to federal and state regulatory representatives. Signature: Printed Name: Adviser CRD Number: 107287 Date: MM/DD/YYYY Title: © 2022 FINRA. All rights resented. FINRA is a registered trademark of the Financial Industry Regulatory Authority, Inc. Privacy i Legal I Terms & Conditions https://crd.finra.org/lad/Content/PrintHist/Adv/Sections/crd_iad_AdvAllSections.aspx?RefNum=9175437628190CF5&viewChanges=&FLNG_PK= 42/42 CM CHANDLER ASSET MANAGEMENT Part 2A of Form ADV: Firm Brochure Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 Telephone: 858-546-3737 Email: Compliance@chandlerasset.com Web Address: www.chandlerasset.com March 29, 2022 This disclosure brochure (the "Brochure") provides information about the qualifications and business practices of Chandler Asset Management, Inc. ("Chandler"). If you have any questions about the contents of this Brochure, please contact us at 858-546-3737 or Compliance@chandlerasset.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. Registration with the Securities and Exchange Commission does not imply any level of skill or training. Additional information about Chandler and its investment adviser representatives is also available on the SEC's website at www.adviserinfo.sec.gov. You can search this site by name or by a unique identifying number, known as a CRD number. Our firm's CRD number is 107287. Page 1 of 26 This Firm Brochure, dated 03/29/2022, provides you with a summary of Chandler's advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This item (Item 2) is used to provide our clients with a summary of new and/or updated information; we will inform you of the revision(s) based on the nature of the information as follows. 1. Annual Update: We are required to update certain information at least annually, within 90 days of our firm's fiscal year end ("FYE") of December 31. We will provide you with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of our FYE or we will provide you with our revised Brochure that will include a summary of those changes in this Item. 2. Material Changes: Should a material change in our operations occur, depending on its nature we will promptly communicate this change to clients (and it will be summarized in this Item). "Material changes" requiring prompt notification will include changes of ownership or control; location or disciplinary proceedings. We may also advise you of other changes based on the nature of the updated information. The following summarizes new or revised disclosures based on information previously provided in our Firm Brochure dated 12/30/2021. Item 4 — Advisory Services — Revised Item 4E to reflect regulatory assets under management as of December 31, 2021. Clients and prospective clients are strongly encouraged to review this Brochure very carefully. Page 2 of 26 Item 1 Cover Page 1 Item 2 Material Changes 2 Item 3 Table of Contents 3 Item 4 Advisory Business 5 Item 4A: Firm Overview 5 Item 4B: Types of Advisory Services 5 Item 4C: Tailoring Advisory Services Offered Directly to Clients 5 Item 4D: Services Offered Through Wrap Fee Programs, Sub -Advisory Arrangements and Dual Contract Sponsored Programs 6 Item 4E: Assets Under Management 7 Item 5 Fees and Compensation 8 Item 5A: Fee Schedules 8 Item 5B: Fee Payment 10 Item 5C: Other Fees and Expenses and Valuation Policy 10 Item 5D: Prepaid Fees 11 Item 5E: Compensation for the Sale of Securities or Investment Products 11 Item 6 Performance -Based Fees and Side -By -Side Management 12 Item 7 Types of Clients 12 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 12 Item 8A: Methods of Analysis & Investment Strategies 12 Item 8B: Material Risks 14 Item 8C: Risks Associated with Particular Types of Securities Used 15 Item 9 Disciplinary Information 17 Item 10 Other Financial Industry Activities and Affiliations 17 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 17 Item 11A: Code of Ethics 17 Item 116: Principal Trading and Agency Cross Trading 18 Item 11C: Personal Trading 18 Item 11D: Participation or Interest in Client Transactions 18 Item 12 Brokerage Practices 19 Item 12A: Broker -Dealer Selection, Compensation & Trade Aggregation 19 Item 12A.1: Research and Other Soft Dollar Benefits 20 Item 12A.2: Brokerage for Client Referrals 21 Item 12A.3: Directed Brokerage 21 Page 3 of 26 Item 12B: Aggregating Client Trades 22 Item 13 Account Reviews 23 Item 13A: Periodic Account Reviews 23 Item 13B: Other Reviews 24 Item 13C: Reporting 24 Item 14 Client Referrals and Other Compensation 24 Item 14A: Other Compensation 24 Item 14B: Client Referrals 24 Item 15 Custody 24 Item 16 Investment Discretion 25 Item 17 Voting Client Securities 25 Item 17A: Proxy Voting 25 Item 17B: Where Client Retains Right to Vote Proxies 26 Item 18 Financial Information 26 Item 18A: Financial Statement Requirement 26 Item 18B: Financial Condition 26 Item 18C: Bankruptcy Disclosure 26 Page 4 of 26 ITEM 4A: FIRM OVERVIEW Chandler Asset Management, Inc. ("Chandler") is an SEC -registered investment adviser and employee -owned business enterprise with its principal place of business located in San Diego, California. Since 1988, Chandler has provided fixed income investment management services to the public sector, as well as to hospitals, foundations, endowments, individuals and corporations. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). • Chandler Asset Management, Inc. Employee Stock Ownership Plan ("ESOP") • Martin Dayle Cassell, CEO ITEM 4B: TYPES OF ADVISORY SERVICES Chandler offers the following advisory services, where appropriate, to certain institutional clients such as public agencies, hospitals and healthcare institutions, corporations or other business entities, foundations and endowments, pension and profit-sharing plans, higher education institutions, and non -institutional clients, such as individuals, high net worth individuals, trusts, estates and charitable organizations. The portfolio management services are offered to clients directly, and through wrap fee programs, sub -advisory relationships, and dual contract sponsored programs. FIXED INCOME PORTFOLIO MANAGEMENT Chandler specializes in fixed income portfolio management, utilizing a variety of investments, such as corporate debt securities (notes and bonds), municipal bonds, U.S. Government Treasury bonds, Government Sponsored Enterprise debt securities (agencies), mortgage -backed securities, asset -backed securities and money market securities, i.e., commercial paper. Please refer to Item 8 for further information on our method of analysis and risks associated with this strategy. MULTI ASSET CLASS PORTFOLIO MANAGEMENT Chandler also offers a Multi Asset Class strategy to clients seeking to attain exposure to a variety of global equity, fixed income and other asset classes through investment in indexed or actively managed mutual funds and exchange -traded funds (ETFs). Please refer to Item 8 for further information on our method of analysis and risks associated with this strategy. CONSULTING SERVICES Chandler also provides more focused investment advice to clients. This advice can pertain to areas that clients consider a concern, such as analysis of a client's existing portfolio, delivery of a report or periodic reports of performance and recommended rebalancing of assets, or a review of the client's investment policy. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker -dealer. ITEM 4C: TAILORING ADVISORY SERVICES OFFERED DIRECTLY TO CLIENTS At the beginning of the client relationship, we have discussions with clients to determine their overall investment goals to develop a specific investment policy for each client and confirm that the selected strategy meets their current needs. During our information gathering process, we review the client's individual objectives, time horizons, risk tolerance, liquidity needs and any investment restrictions they may want to place on the assets in their account. As appropriate, we also review and discuss a client's prior investment history, and any other relevant issues. Once these reviews and discussions take place, the client enters into a written agreement Page 5 of 26 directly with Chandler for the management of certain assets. Clients are responsible for informing us of any changes to their guidelines, individual needs and/or restrictions and should do so promptly upon such change. We do not assume any responsibility for the accuracy of the information provided by the client. Generally, we manage clients' advisory accounts on a discretionary basis, but will manage a client's account on a non -discretionary basis, if requested by a client. Please refer to Item 16 for further information on our discretionary authority of client accounts. In addition to the types of securities utilized by Chandler for its Fixed Income and Multi Asset Class advisory services outlined above, we also provide advice on or manage other investments for clients, particularly when a client already has securities in his/her portfolio at the time the client opens an account with Chandler. These generally include, but are not limited to: ■ Exchange -listed securities ■ Securities traded over-the-counter ■ Certificates of deposit Some types of investments involve certain additional degrees of risk; therefore, they will only be implemented or recommended when consistent with the client's stated investment goals, tolerance for risk, liquidity and suitability requirements. Please refer to Item 8 for further information on the risks associated with investments made in clients' accounts. Clients will always retain individual ownership of all securities through their selected custodian. GUIDED PORTFOLIO STRATEGIES ("GPS") The GPS program provides fixed income portfolio management for public agency clients who cannot meet the institutional minimum required for Chandler's full -service customized portfolio management. GPS is a streamlined service model whereby the client receives fixed income portfolio management in a separate account custodied at a qualified third -party custodian. Clients may choose between two of Chandler's established, short duration investment strategies developed to meet the investment needs of municipal investors. Chandler will manage the portfolios in compliance with State or Government code sections related to permitted investments for municipalities and will not accommodate additional client restrictions or requests for customizations to the portfolio or our standard reporting packages. Services are limited to the scope defined in the client Agreement. To be eligible for this program, the client must have a minimum of $2 million in investable assets. Please refer to Item 5 for program fees. ITEM 4D: SERVICES OFFERED THROUGH WRAP FEE PROGRAMS, SUB -ADVISORY ARRANGEMENTS AND DUAL CONTRACT SPONSORED PROGRAMS Chandler participates as an investment manager in selected wrap fee programs ("Wrap Programs"). Generally, under these programs a client enters into an agreement with the wrap program sponsor to provide the following services to such clients ("Wrap Clients"): a) assisting the Wrap Client in determining which investment strategy and investment manager best meet their goals and objectives, b) on -going monitoring of account performance, c) custodial services, and d) execution of account transactions. These services and the services provided by the investment manager are generally provided for one all-inclusive fee ("Wrap Fee"). From the Wrap Fee, the wrap program sponsor pays the investment manager (for example Chandler) for their services. Currently, Chandler participates as an investment manager in the following Wrap Programs: ■ Managed Accounts Select Program sponsored by Charles Schwab Corporation ("Schwab") ■ Separately Managed Accounts ("SMA") Program sponsored by Envestnet Asset Management, Inc. ("Envestnet") ■ Unified Managed Accounts ("UMA") Program sponsored by Envestnet. For more details on these specific programs, clients should review the respective sponsor's Wrap Fee Program Brochure prior to investing. In each of these programs, a representative of the program sponsor or an independent financial advisor will work Page 6 of 26 with the Wrap Client to complete an investment questionnaire or other investment objective documentation and determine the appropriate investment strategy and manager. While Chandler is not responsible for client suitability for the Wrap Program, we will perform a general review of the Wrap Client's investment objective documentation, if provided by the wrap sponsor, to help us ensure that our strategy selected by the Wrap Client appears suitable. Participation in these wrap programs is subject to account minimums specified in the respective Wrap Fee Program Brochure. Depending on the selected program, these minimums range from $150,000 to $500,000. Chandler also enters into selected sub -advisory arrangements or participates as a manager in selected dual contract sponsored programs. In such instances, Chandler typically provides advisory services to a client under a sub -advisory arrangement with an unaffiliated registered investment adviser ("RIA"), or under an investment management agreement with an advisory client who also has an advisory agreement with an unaffiliated RIA or financial consultant intermediary. Chandler may or may not have a service agreement with the sponsor of a dual -contract program. With the exception of certain pre-existing fixed income portfolio management clients, typically Chandler is granted full investment discretion (subject to limitations on the firm's discretion to select broker -dealers for portfolio transactions, as discussed below) and manages a client's portfolio based on the individual needs of that client, as communicated through the sponsor, the RIA or other designated intermediary. The relevant information is submitted to Chandler and a determination is made as to whether participation in this program is appropriate for the client. On an ongoing basis, the participating client's financial consultant is responsible for obtaining and communicating to us any changes in the client's financial circumstances and/or objectives, including modifications to any client -imposed restrictions, if applicable. Currently Chandler provides investment management services as an investment manager in the following dual - contract or sub -advisory sponsored programs: • Charles Schwab Corporation ("Schwab") Market Place • Fidelity Investments ("Fidelity") Separate Account Network • Merrill Lynch ("ML") Managed Account Services • TD Ameritrade Institutional ("TDAI") Separate Account Exchange • Wells Fargo Advisors ("WFA") Private Advisor Network ("PAN") ITEM 4E: ASSETS UNDER MANAGEMENT Assets Under Management As of December 31, 2021 Assets Managed Discretionary $21,726,632,304 Non -Discretionary Total $4,058,341,663 Page 7 of 26 $25,784,973,967 PE VSATI ITEM 5A: FEE SCHEDULES The annual fee for non -wrap fee client accounts is charged as a percentage of assets under management, according to the following schedules: Fixed Income Portfolio Management for Institutional Accounts Assets Under Management All Assets Annual Asset Management Fee 0.15 of 1% (15 basis points) A minimum of $20 million in assets under management is required for this service. Chandler reserves the right to negotiate alternative minimum account size and fees on a case -by -case basis. Chandler will aggregate certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Guided Portfolio Strategies "GPS" Portfolio Management for Institutional Accounts Assets Under Management All Assets Annual Asset Management Fee 0.35 of 1% (35 basis points) A minimum of $2 million in assets under management is required for this service. Chandler reserves the right to negotiate alternative minimum account size and advisory fees on a case -by -case basis. Chandler will aggregate certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Multi Asset Class Portfolio Management for All Accounts Assets Under Management All Assets Annual Asset Management Fee 0.25 of 1% (25 basis points) A minimum of $1 million in assets under management is required for this service. Chandler reserves the right to negotiate alternative minimum account size and advisory fees on a case -by -case basis. Chandler will aggregate certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. FIXED INCOME PORTFOLIO MANAGEMENT FOR NON -INSTITUTIONAL ACCOUNTS; DUAL CONTRACT SPONSORED PROGRAMS OR SUB -ADVISORY ARRANGEMENTS Chandler's fees will vary with a maximum of 0.35 of 1% depending upon the program and strategy in which the client is participating. Chandler's fees for non -institutional clients are typically paid monthly, in arrears, but can vary based on the terms of the governing agreements. Chandler's fees earned pursuant to dual contract programs or sub -advisory arrangements will be paid in accordance with the terms of each such program. For non -institutional accounts (e.g., high net worth), a minimum of $1 million in assets under management is required for this service. For dual contract and sub -advisory relationships, account minimums range from $150,000 to $500,000 depending on the program and the composition of the assets being managed. Account size may be negotiable under certain circumstances. Chandler groups certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Page 8 of 26 FIXED INCOME PORTFOLIO MANAGEMENT FOR WRAP FEE PROGRAMS Chandler will be compensated through a portion of the total wrap fee charged by the program sponsor (with Chandler's fees ranging up to a maximum of 0.35 of 1%. The all-inclusive wrap fee collected by a wrap sponsor includes Chandler's advisory fee. Chandler does not control the fees or the billing arrangements in any Wrap Program. Chandler is paid its fees for Schwab's Managed Accounts Select Program monthly, in arrears, while our fees for Envestnet's SMA and UMA Programs are paid quarterly, in arrears. Fees paid for ML's Managed Account Services Program are paid quarterly in advance. The wrap or UMA sponsor pays Chandler its advisory fee on behalf of the Wrap or UMA Client. For a complete description of the fee arrangement, including billing practices, minimum account requirements and account termination provisions, clients should review the respective sponsors' Wrap Fee Program Brochure. Clients participating in these programs should also review important disclosures about Chandler's brokerage practices described in Item 12 below. CONSULTING SERVICES FEES Chandler's Consulting Services fees will be determined based on the nature of the services being provided and the complexity of each client's circumstances. All fees are agreed upon prior to entering into a contract with any client. Chandler's Consulting Services fees are calculated in one or both of two ways: 1. On a fixed fee basis, subject to the specific arrangement reached with the client; and/or 2. On an hourly basis, ranging up to $500.00 per hour. An estimate for the total hours is determined at the start of the advisory relationship. The length of time it will take to complete Consulting Services will depend on the scope and terms of the engagement. Fees are due and payable upon completion of the Consulting Service or on an agreed upon payment schedule. A retainer may be requested upon completion of Chandler's fact-finding session with the client; however, advance payment will never exceed $1,200 for work that will not be completed within six months. There is no minimum fee for Chandler's Consulting Services. GENERAL FEE INFORMATION PERTAINING TO INSTITUTIONAL AND NON -INSTITUTIONAL ACCOUNTS, DUAL CONTRACT SPONSORED PROGRAMS AND SUB -ADVISORY ARRANGEMENTS Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to Chandler's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our firm's minimum account requirements and advisory fees differ among clients. Advisory Fees in General: Clients should note that similar advisory services may or may not be available from other registered investment advisers for similar or lower fees. Chandler's clients are not required to pay any start-up or closing fees; there are no penalty fees. Termination of the Advisory Relationship: A client agreement between a client and Chandler may be canceled at any time, by either party, for any reason upon receipt of written notice. As disclosed in Item 5D below, certain fees may be paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded to the client. In calculating a client's reimbursement of fees, we will pro rate to the effective date of termination on the basis of actual days elapsed. Fee Calculation: Chandler's annual advisory fee is billed monthly or in some instances quarterly, in arrears, and is calculated based on the average market value of a client's account for the billing period, including accrued interest unless indicated otherwise in the client agreement. Cash and cash equivalent balances are included in the total market value calculation unless noted otherwise in the client agreement. We will value securities or investments in the portfolio in a manner determined in good faith to reflect fair market value. Chandler uses an independent third -party pricing source to value client securities. Limited Negotiability of Advisory Fees: Although Chandler has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a case -by -case basis. Client facts, Page 9 of 26 circumstances and needs will be considered in determining the fee schedule. These include the complexity of the client, the assets to be placed under management, the anticipated future additional assets; the existence of any related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the written agreement between Chandler and each client. We group certain related client accounts for the purposes of achieving the minimum account size requirements and determining the annual advisory fee. Chandler reserves the right to reduce or waive advisory fees for services provided to related persons of the firm and their immediate family members. Such rates are not available to all of Chandler's advisory clients. GENERAL FEE INFORMATION PERTAINING TO WRAP FEE CLIENT ACCOUNTS Fee Calculation: Chandler's annual advisory fees charged to wrap fee program clients are calculated and billed by the respective program sponsor. As Chandler does not control the billing arrangements in these programs, clients should review the applicable disclosure documents for a comprehensive understanding of the fees charged and the billing practices of the program. What services are covered by the Wrap Program fees? Wrap Program fees typically pay for our firm's advisory services to participating clients, administrative expenses, custody charges for clients' assets custodied at the Wrap Program's designated custodian and brokerage services for participating client accounts to the extent trades are conducted through the Wrap Program's designated broker -dealer. What services are not covered by the Wrap Program fees? Wrap Program fees do not cover brokerage to the extent trades are conducted through brokers or dealers other than the designated broker or dealer and custody charges if client assets are custodied anywhere other than the designated custodian. The program fees do not include expenses of mutual funds and electronically traded funds such as fund management fees charged to each fund's investors. Chandler's fixed income transactions are generally executed by the broker - dealer on a net basis, which means the execution costs (e.g., commissions) are included in the purchase or sale price of the security. WRAP FEE PROGRAMS FEES: CLIENTS PARTICIPATING IN WRAP FEE PROGRAMS WILL BE CHARGED VARIOUS PROGRAM FEES IN ADDITION TO THE ADVISORY FEE CHARGED BY OUR FIRM. CLIENTS SHOULD CAREFULLY EVALUATE SUCH AN ARRANGEMENT TO DETERMINE IF THE WRAP FEE PAID FOR THE SERVICES PROVIDED MAY OR MAY NOT EXCEED THE AGGREGATE COST OF SUCH SERVICES IF THEY WERE TO BE PROVIDED SEPARATELY. ITEM 5B: FEE PAYMENT Generally, each non -wrap client's custodian debits Chandler's advisory fees from the client's account and pays such fee directly to us upon receipt of an invoice, unless otherwise arranged by the client. Clients entering into written agreements with Chandler have discretion over whether or not Chandler may directly debit fees from the client's account. Clients who do not permit direct debiting will be invoiced directly with payment due upon receipt of the invoice. Sub -advisory and dual contract client agreements require the client to authorize the custodian to pay Chandler its advisory fees directly from the client's account, which will be paid in arrears in accordance with the terms of each such program. Fees for Schwab's Managed Accounts Select Program are paid monthly, in arrears, while our fees for Envestnet's SMA and UMA's Programs are paid quarterly, in arrears. ML's Managed Account Services Program are paid quarterly in advance. All of these programs require a client to authorize the sponsor to deduct the fees directly from the client's account to pay Chandler. For a complete description of the fee arrangement including billing practices and account termination provisions for wrap fee programs, clients should review the respective sponsors' Wrap Fee Program Brochure. ITEM 5C: OTHER FEES AND EXPENSES AND VALUATION POLICY Mutual Fund Fees: All fees paid to Chandler for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. The fees and expenses charged by mutual funds and ETFs are described in each fund's prospectus. These fees will generally include a Page 10 of 26 management fee, other fund expenses, 12b-1 fees and possible distribution or redemption fees. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Importantly, clients should review both the fees charged by mutual funds and ETFs and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Chandler is not affiliated with any mutual funds or ETFs, does not share in the fees charged by mutual funds and ETFs, does not participate in the investment decisions regarding the portfolios of mutual funds and ETFs and is not liable regarding such investments. The fees and related expenses charged by mutual funds and ETFs can be found in the respective fund's prospectus and statement of additional information, which should be read carefully before investing. Short Term Idle Cash Investment: Chandler can move some or all of the non -invested cash in a client's account to a money market mutual fund that may generate an interest return. If the cash is invested through a mutual fund, there may be times when an affiliate of the client's custodian may be the manager of such fund and would receive separate management fees from the mutual fund. Chandler is not affiliated with any such custodian, does not share in that fee, does not participate in the investment decisions of the mutual fund portfolio and is not liable regarding such investments. Custodian and Broker Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker -dealers, including, but not limited to, any transaction charges imposed by a broker -dealer that effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Brochure for additional information. From time to time, Chandler recommends a custodian to clients who do not have an existing custodial relationship established. Among others, Chandler generally recommends Union Bank, Bank of New York/Mellon, US Bank, Wells Fargo, Bank of America, or Charles Schwab & Co. Some of these custodians offer special pricing for institutional clients of Chandler. Chandler does not receive any compensation from the custodians we refer to our clients. The rates offered will depend on the size of the assets or type of account. Clients retain full discretionary authority over the selection of the custodian to be used. Valuation Policy. For all publicly traded securities held in clients' accounts, Chandler receives daily prices electronically from a third -party provider, which are reviewed internally monthly by designated investment personnel. When it is believed that the price provided is not correct or for times when the third party does not provide a price, Chandler will obtain pricing from a different third -party pricing source. This creates a conflict of interest since this practice could incentivize the designated investment personnel to select a pricing source that reflects a higher price per share for the security. To address this conflict, Chandler maintains detailed written policies and procedures regarding valuation of clients' securities, which includes among other things, a list of approved third -party pricing vendors used by Chandler and reviews of price changes by the CIO and CCO. ITEM 5D: PREPAID FEES Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. Fees for ML's Manager Account Services Program are billed quarterly in advance. For a complete description of the fee arrangement, including billing practices and account termination provisions, clients should review the respective sponsors' Wrap Fee Program Brochure or other applicable disclosure document(s). ITEM 5E: COMPENSATION FOR THE SALE OF SECURITIES OR INVESTMENT PRODUCTS Chandler is not affiliated with any broker -dealers or mutual fund companies, and therefore we do not receive any compensation for the purchase or sale of securities or investment products used in client accounts. Page 11 of 26 I ITEM 6 PERFORMANCE -BASED FEES AND SIDE -BY -SIDE MANAGEMENT Chandler does not charge performance -based fees (i.e., fees calculated based on a share of capital gains on or capital appreciation of the client's assets or any portion of the client's assets). Consequently, we do not engage in side -by -side management of accounts that are charged a performance - based fee with accounts that are charged another type of fee (such as assets under management). 'ES OF CLIENTS Chandler provides advisory services to the following types of clients: • State, local or other municipal government entities • Healthcare institutions • Higher education institutions • Charitable organizations • Pension and profit-sharing plans (other than plan participants) • Individuals (other than high net worth individuals) only through Wrap and Dual Contract programs • High net worth individuals • Corporations or other business entities not listed above • Retirement Accounts As disclosed above in Item 5A of this Brochure, we have established certain initial minimum account asset requirements to maintain an account, based on the nature of the service(s) being provided. For a more detailed understanding of those requirements, please review the disclosures provided in each applicable service. 8 HODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ITEM 8A: METHODS OF ANALYSIS & INVESTMENT STRATEGIES METHODS OF ANALYSIS Chandler uses all or any combination of the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt to measure the intrinsic value of a security or a market sector by looking at broad economic and financial factors (including the overall economy, industry conditions, and the market's valuation of the security or market sector) to identify securities or market sectors that we believe are fairly valued or undervalued. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the security. Technical Analysis. We analyze past market movements and may occasionally apply that analysis to choose the price at which we wish to purchase or sell a given security. While we may seek a specific price for a security, technical analysis is never the main determinant of our purchase or sell process. A risk in using technical analysis is that the methods or models we use may not result in the best price of a given day. Quantitative Analysis. We use a proprietary quantitative model (Horizon Analysis Model) that utilizes mathematical analysis to estimate the impact of interest rate changes on individual securities and portfolios of securities. The results of our quantitative analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions Page 12 of 26 that prove to be incorrect. Qualitative Analysis. We use qualitative analysis to evaluate individual securities, focusing on other non -quantifiable factors, such as quality of management, not readily subject to measurement, and incorporate that analysis into our security selection process. A risk in using qualitative analysis is that our subjective judgment may prove incorrect. Asset Allocation. We generally focus on identifying an appropriate allocation of securities, maturities, market sectors and yield curve positioning suitable for the client's investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the allocation will change over time due to market movements in the various sectors, which, if not corrected, may no longer be appropriate for the client's goals. Mutual Fund and/or ETF Analysis. In selecting mutual funds and ETFs for Multi Asset Class portfolios, we look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF to determine if there is significant overlap in the underlying investments held in other fund(s) in the client's portfolio. We monitor the funds and ETFs to determine if they continue to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, potentially increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client's portfolio. Risks for all forms of analysis Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell as well as other purchased or publicly available sources of information about these securities are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. FIXED INCOME PORTFOLIO MANAGEMENT INVESTMENT STRATEGIES We believe that a conservative, risk -controlled approach to fixed income management will provide both steady incremental outperformance, and low relative volatility. The disciplined process we employ in an effort to realize this philosophy is generally grounded in four key decisions: • Constraint of portfolio duration within a narrow range relative to the benchmark in order to limit exposure to market risk • Strategic allocations to key sectors to add value relative to the benchmark • Active management of term structure to add value in different yield curve environments • Security selection based on rigorous credit and relative value analysis and broad diversification of non - government issuers. Within our fixed income strategy, we use the following sub -strategies in managing client accounts, provided that such sub -strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: • Duration Constraints. We adhere to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. Our portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. Page 13 of 26 The risk of constraining duration is that the client may underperform a neutral duration portfolio as bond prices move up or down. Sector Allocation. We allocate client assets to various sectors of the fixed income market, including US Treasury obligations, federal agency securities, corporate notes, mortgage -backed securities and others, based on our quantitative and qualitative analysis in order to manage client exposure to a given sector and to provide exposure to sectors we believe have good value. The risk of sector allocation is that clients may underperform depending on the allocation to any particular sector as those prices rise or fall. Security Selection. A proprietary credit evaluation process drives our security selection process. The system uses both internally and externally generated credit research to evaluate securities we are considering for purchase. Based on research we conduct internally; our Credit Committee selects securities for our Approved list. The ultimate decision to purchase or sell a security is based on the firm's evaluation of the current price for the security. The risk of security selection is that the methods of analysis employed will not provide accurate measurement of the risk association with each individual security. Long-term purchases. We purchase securities with the idea of holding them in the client's account for a year or longer. Typically, we employ this sub -strategy when: ■ we believe the securities to be well valued, and/or ■ we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our analysis is incorrect, a security may decline sharply in value before we make the decision to sell. MULTI ASSET CLASS PORTFOLIO MANAGEMENT INVESTMENT STRATEGIES We invest in Multi Asset Class portfolios for clients with certain objectives and risk tolerances. This strategy begins with assumptions that the firm develops about the expected long-term performance of various asset classes including domestic and foreign stocks and bonds, real estate, commodities, cash, and others. Based on the expected returns and risk characteristics of these asset classes, we prepare an asset allocation suitable for the individual client's objectives and risk tolerances. The investment vehicles that we currently employ for this strategy are mutual funds or exchange -traded funds (ETFs) that are designed to track market returns and volatilities. The mutual funds or ETFs will be selected based on any or all of the following criteria: the fund's performance history; the industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. Portfolio weighting between funds and market sectors will be determined by each client's individual needs and circumstances. Once the client's portfolio is in place, we rebalance it each quarter to the client's target allocation. On an annual basis, at a minimum, we review the costs and performance of our selected investment vehicles to ensure the funds or ETFs are performing as we expect. The risks of this strategy include (1) that our analysis of long-term return expectations will not be correct; (2) that the portfolios will not be properly rebalanced; (3) that the investment vehicles we employ will not track market returns and volatility as we expect. Detailed information on the risks associated with the investments made by the mutual funds or ETFs, will be outlined in each fund's prospectus. ITEM 8B: MATERIAL RISKS Risk of Loss. Securities investments are not guaranteed, and a client may lose money on their investments. We ask that each client work with us to help us understand their tolerance for risk. Investors should be aware Page 14 of 26 that investment prices fluctuate as the securities are affected by economic and other factors. As a result, the value of your investment may increase or decrease. Bonds held to maturity will return the full par or face value amount to the bondholder at maturity (absent a default); however, those sold prior to maturity are subject to gain or loss depending on the market price at the time of sale. For risks specific to a particular method of analysis or investment strategy, please see Item 8A above. For risks specific to a particular type of security, please see Item 8C below. ITEM 8C: RISKS ASSOCIATED WITH PARTICULAR TYPES OF SECURITIES USED RISKS ASSOCIATED WITH FIXED INCOME SECURITIES Chandler specializes in investment grade fixed income portfolio management. Despite the generally conservative nature of many fixed income investments, there are a variety of risks associated with fixed income investing. Fixed income securities represent monies lent by investors to corporate and government institutions. Risks vary according to the type of fixed income investment purchased along with the general level of interest rates in the economy. The risks commonly associated with fixed income securities are: Market Risk: The price of the security may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security's particular underlying circumstances. ■ Interest Rate Risk: The risk that the value of an interest -bearing investment will change due to changes in the general level of interest rates in the market. The market value of a bond fluctuates inversely to the change in interest rates; that is, as interest rates rise, bond prices fall and vice versa. Interest rate risk is commonly measured by a bond's duration; the greater a bond's duration, the greater the impact on price of a change in interest rates. Investors may incur a gain or loss from bonds sold prior to the final maturity date. Credit Risk: The risk that principal and/or interest on a fixed income investment will not be paid in a timely manner or in full due to changes in the financial condition of the issuer. Generally, the higher the perceived credit risk, the higher the rate of interest investors will receive on their investment. Many bonds are rated by a third party Nationally Recognized Statistical Rating Organization (NRSRO), for example, Moody's Investor Services or Standard & Poor's Inc. While ratings may assist investors to determine the creditworthiness of the issuer, they are not a guarantee of performance. Reinvestment Risk: The risk that interest and principal payments from a bond will be reinvested at a lower yield than that received on the original bond. During periods of declining interest rates, bond payments may be invested at lower rates; during periods of rising rates, bond payments may be invested at higher rates. Call Risk: The risk that a bond will be called by its issuer. A callable bond has a provision which allows the issuer to purchase the bond back from the bondholders at a predetermined price. Generally, issuers call bonds when prevailing rates are lower than the cost of the outstanding bond. Call provisions allow an issuer to retire high -rate bonds on a predefined call schedule. Prepayment Risk: Some types of bonds are subject to prepayment risk. Similar to call risk, prepayment risk is the risk that the issuer of a security will repay principal prior to the bond's maturity date, thereby changing the expected payment schedule of the bonds. Prepayment risk is particularly prevalent in the mortgage -backed bond market, where a decline in interest rates can trigger loan holders to pre -pay their mortgages. When investors in a bond comprised of the underlying pool of mortgages receives his or her principal back sooner than expected, they may be forced to reinvest at prevailing, lower rates. Page 15 of 26 • Liquidity Risk: The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in a wide bid -ask spread or large price movements. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Opportunity Cost Risk: The risk that an investor may forego profits or returns from other investments. RISKS ASSOCIATED WITH MUTUAL FUNDS AND ETFS As discussed in further detail in Item 4B above, Chandler also offers a Multi Asset Class strategy to clients seeking to attain balanced returns. This strategy provides exposure to various equity, fixed income and other asset classes through investments in indexed or actively managed mutual funds and exchange traded funds ("ETFs"). Chandler is not affiliated with any such mutual fund or ETF company, does not share in any fees charged by a mutual fund or ETF and does not participate in any investment decisions relating to the management of a mutual fund or ETF portfolio. Mutual Funds A mutual fund is a company that pools money from many investors and invests the money in different securities or assets based on the investment strategy or goals of the particular fund. Each share of a mutual fund represents an investor's proportionate ownership of the fund's holdings and the income those holdings generate. The risks most commonly associated with mutual funds are: Market Volatility: Investment returns will fluctuate and are subject to market volatility, so that a client's shares, when redeemed or sold, may be worth more or less than their original cost. Past performance is no guarantee of future results. Tracking Error for Index Funds: Index mutual funds seek to track the returns of a market benchmark such as the S&P 500 index, by holding the same securities or a representative sample. A risk of using index mutual funds is that the fund may not be able to track its benchmark closely creating the potential for lower returns than the benchmark. Lack of Control/Transparency: Clients typically are not given the exact make-up of a fund's portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades. Price Uncertainty: With an individual stock, a client can obtain real-time pricing information with relative ease by either checking financial websites or by calling a broker. With a mutual fund, the price at which a client purchases or redeems shares will typically depend on the fund's NAV, which the fund might not calculate until many hours after a client has placed their order. Mutual funds generally calculate their NAV at least once per business day. International Risk: Chandler invests in Mutual Funds offered by US based fund companies that invest in non -US companies and markets, which entail additional risks. Non -US markets may be more volatile due to a variety of factors including, less liquidity, transparency and oversight of companies or assets. Values of non -US investments may fluctuate due to changes in currency exchange rates. Non -US companies are also subject to risks that come with political and economic stability that may affect their respective countries. These risks may be greater in emerging market countries. Exchange -Traded Funds (ETFs) ETFs are investment funds that trade on stock exchanges much like stocks and will fluctuate in market value. ETFs also may trade at prices above or below the ETFs net asset value. Brokerage commissions and ETF expenses will reduce returns. Additionally, frequent trading of ETFs could significantly increase commissions and other costs such that they may offset any savings from low fees or costs. Equity based ETFs are subject to risks similar to those of stocks and fixed income ETFs are subject to risks similar to those of bonds. Page 16 of 26 The risks most commonly associated with ETF securities are: Market Volatility: Investment returns will fluctuate and are subject to market volatility, so that a client's shares, when redeemed or sold, may be worth more or less than their original cost. Past performance is no guarantee of future results. Tracking Error for Index ETFs: Index ETFs seek to track the returns of a market benchmark such as S&P 500 index, by holding the same securities or a representative sample. A risk of using index ETFs is that the fund may not be able to track its benchmark closely creating the potential for lower returns than the benchmark. Lack of Control/Transparency: Clients typically are not given the exact make-up of a fund's portfolio at any given time, nor can they directly influence which securities the fund manager buys and sells or the timing of those trades. Liquidity Risk: The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in a wide bid -ask spread or large price movements. International Risk: Chandler invests in ETFs offered by US based fund companies that invest in non - US companies and markets, which entail additional risks. Non -US markets may be more volatile due to a variety of factors including, less liquidity, transparency and oversight of companies and assets. Values of non -US investments may fluctuate due to changes in currency exchange rates. Non -US companies are also subject to risks that come with political and economic stability that may affect their respective countries. These risks may be greater in emerging market countries. Chandler does not represent, guarantee or imply that the services or methods of analysis employed by us can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. I ITEM 9 DISCIPLINARY lNFoR TIoN We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Neither our firm nor our Management Persons have any reportable disciplinary events to disclose. I ITEM 10 OTHERFINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Our firm and our related persons are not engaged in other financial industry activities and have no other industry affiliations. ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AAA PERSONAL TRADING ITEM 11A: CODE OF ETHICS Our firm maintains a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Chandler and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm's access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement), an initial public offering and certain other securities. Our Code also provides for oversight, enforcement, and recordkeeping provisions. Page 17 of 26 Chandler's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any access to non-public information, all employees are periodically reminded that such information may not be used in a personal or professional capacity. Our Code of Ethics is distributed to all supervised persons of Chandler whenever revisions are made or no less frequently than annually, at which time all employees are required to provide a written acknowledgement and attestation of their intent to abide by Chandler's Code provisions. In addition, firm -wide annual training regarding Chandler's Code of Ethics is provided by Compliance. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to Compliance@chandlerasset.com, or by calling us at 858-546-3737. ITEM 11B: PRINCIPAL TRADING AND AGENCY CROSS TRADING Chandler and individuals associated with our firm are prohibited from engaging in principal transactions. Chandler and individuals associated with our firm are prohibited from engaging in agency cross transactions. ITEM 11C: PERSONAL TRADING Chandler and/or individuals associated with our firm can from time to time, buy or sell for their personal accounts, securities identical to or different from those recommended to our clients. In addition, any related person(s) could potentially have an interest or position in a security(ies) which may also be recommended to a client. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients, and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. It is also designed to help prevent employees from benefiting from transactions placed on behalf of advisory clients. For additional information on how we address the conflicts of interest that arise in connection with personal trading, please see Item 11D below. ITEM 11 D: PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS From time to time, Chandler will aggregate trades for our self or our employees with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro -rata basis. In the instances where there is a partial fill of a particular aggregated order, we will allocate all purchases pro -rata, with each account paying the average price. Our employee accounts will be excluded in such a pro -rata allocation. Because the situations outlined above represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm's Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. 3. No principal or employee may benefit from transactions placed on behalf of advisory accounts. 4. Our firm requires prior approval for any IPO, private placement investments and certain other securities by related persons of the firm. 5. We maintain a list of all reportable securities holdings for our firm, and anyone associated with this advisory practice that has access to advisory recommendations ("access person"). These holdings are reviewed on a regular basis by our firm's Chief Compliance Officer or designee. Page 18 of 26 6. We have established procedures for the maintenance of all required books and records. 7. Clients may decline to implement any advice rendered, except in situations where our firm is granted discretionary authority. 8. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 9. We require delivery and acknowledgement of the Code of Ethics by each supervised person (as defined by the Code) of our firm. 10. We have established policies requiring the reporting of Code of Ethics violations to our senior management. 11. Any individual who violates any of the above restrictions may be subject to sanctions, which may include termination of employment. I ITEM 12 BROKERAGE i RAGTICES ITEM 12A: BROKER -DEALER SELECTION, COMPENSATION & TRADE AGGREGATION FIXED INCOME & MULTI ASSET CLASS PORTFOLIO MANAGEMENT Chandler requires discretionary clients to provide us with written authority to determine broker -dealer selection and commission costs that will be charged to these clients for transactions placed in their account(s). Broker -dealers are selected by Chandler based on best execution, a combination of most favorable price and the quality of execution. In selecting a broker to execute a transaction for a client, Chandler considers a variety of other factors, including (but not limited to) the following: • the broker -dealer's capital depth; • the broker -dealer's market access; • the nature of the security or instrument being traded; ■ the size and type of transaction; • the nature and character of the markets for the security or instrument to be purchased or sold; • the desired timing of the transaction; • the execution, clearance and settlement capabilities of the broker -dealer selected, and others considered; • the reputation and perceived soundness of the broker -dealer and others considered. • Chandler's knowledge of any actual or apparent operational problems with the broker -dealer; and • the reasonableness of the commission for specific transactions. While Chandler generally seeks competitive commission rates and dealer spreads, it may not necessarily pay the lowest commission. Transactions may involve specialized services on the part of the broker -dealer and thereby justify higher commissions than would be the case with other transactions requiring more routine services. Regarding commission rates paid, Chandler's fixed income transactions are generally executed by the broker - dealer on a net basis, which means the execution costs (e.g., commissions) are included in the purchase or sale price of the security. Equity and ETF transactions will be charged commissions. FIXED INCOME PORTFOLIO MANAGEMENT IN WRAP FEE OR SUB -ADVISORY PROGRAMS Managed Accounts Select Program Chandler participates in the Schwab Institutional ("SI") services program offered to independent investment advisers by Charles Schwab & Company, Inc. (Schwab), a FINRA registered broker -dealer unaffiliated with Chandler. Wrap fee clients participating in this program are required to utilize Schwab as the custodian for their assets managed within the program. As part of the SI program, Chandler receives benefits that it would not receive if it did not offer investment advice (See the disclosure under Item 12A.1 of this Brochure). Page 19 of 26 Chandler arranges for all securities transactions in wrap program accounts to be executed through the sponsoring party, subject to best execution considerations described above. If Chandler determines that best execution considerations require trading with brokers other than the sponsoring party, clients can incur additional trading costs. These costs area factor in Chandler's best execution analysis. Chandler has established a prime brokerage account relationship with Schwab through which it can purchase fixed income products directly from third parties for clients and maintain custody at Schwab. In this situation, Chandler will select those brokers or dealers which will provide the best services at the lowest commission rates possible. The reasonableness of brokerage costs, commissions and mark-up/mark-downs is based on the broker -dealer's ability to provide professional services, competitive execution, and other services that will help Chandler in providing investment management services to clients. Thus, for fixed income transactions, Chandler may request that it be provided with written authority to determine the broker -dealer to use for client fixed income transactions and the costs that will be incurred by clients for these transactions. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change/amend these limitations as required. Such amendments shall be submitted in writing. There are times when client trades in fixed income securities are aggregated with transactions for other advisory clients to achieve better pricing and commission costs. Fixed income trades will be allocated on a pro -rata basis in the best interest of the client as set forth in Chandler's policy and procedures manual. Envestnet Separately Managed and Unified Managed Accounts Programs Chandler participates as a separate account manager in Envestnet's Separately Managed Accounts (SMA) and Unified Managed Accounts (UMA) Programs offered to independent investment advisers by Envestnet Asset Management, Inc., an SEC registered investment adviser unaffiliated with Chandler. SMA and UMA Program clients are required to utilize Charles Schwab & Company, JP Morgan, Pershing Advisor Solutions, or Fidelity as the custodian for their assets managed within the program. Chandler arranges for all securities transactions in SMA and UMA program accounts through the sponsoring party subject to best execution considerations described above. If Chandler determines that best execution considerations require trading with brokers other than the sponsoring party or client custodian, clients could incur additional trading costs. These costs are a factor in Chandler's best execution analysis. ITEM 12A.1: RESEARCH AND OTHER SOFT DOLLAR BENEFITS Chandler's soft dollar policy prohibits us from entering into third party soft dollar arrangements. We are providing these additional disclosures as we believe clients should understand related issues surrounding soft dollars. The term soft dollars generally refers to arrangements whereby a discretionary investment adviser is allowed to pay for and receive research, research -related or execution services from a broker -dealer or third -party provider, in addition to the execution of transactions, in exchange for the brokerage commissions from transactions for client accounts. As disclosed in Item 4D of this Brochure, clients participating in the Schwab Managed Account Select wrap fee program are required to utilize Schwab as the custodian of their assets being managed within that program. Schwab Institutional provides Chandler with access to its institutional trading and operations services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors at no charge to them so long as a specified minimum, generally $10 million, of the advisor's clients' account assets are maintained at Schwab Institutional. These services are not contingent upon our firm committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab's brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction -related or asset - based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Institutional also makes available to our firm other products and services that create a benefit to Chandler but not a direct benefit to our clients' accounts. Many of these products and services are used to service all or some substantial number of our client accounts, including accounts not maintained at Schwab. Schwab's products and services that assist us in managing and administering our clients' accounts include Page 20 of 26 software and other technology that: • provide access to client account data (such as trade confirmations and account statements); • facilitate trade execution and allocate aggregated trade orders for multiple client accounts; ■ provide research, pricing, and other market data; • facilitate payment of our fees from clients' accounts; and • assist with back -office functions, recordkeeping, and client reporting. Schwab Institutional also offers other services intended to help us manage and further develop our business enterprise. These services include: • 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. Although Chandler does not utilize such services, Schwab can also make available, arrange and/or pay third - party vendors for the types of services rendered to Chandler. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third -party providing these services to our firm. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend clients custody their assets at Schwab, we consider the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a potential conflict of interest. However, Chandler has a fiduciary responsibility to always place client interests before our own and we will only recommend Schwab to clients where we believe it would be beneficial to those clients. Additionally, when placing trades with brokers, there are times when Chandler places certain trades with a third - party approved broker that is providing brokerage and research services to us ("Approved Broker"). Brokerage and research services provided by Approved Brokers can include, among other things, effecting securities transactions and performing services incidental thereto (such as clearance, settlement, and custody) and providing proprietary research (i.e., created by the Research Broker). The research can pertain to the economy, industries, sectors of securities, individual companies, statistical information, political and/or developments, credit, and risk measurement, and/or performance analysis. In selecting a broker for trade placement, Chandler can place transactions with Research Brokers that charge commissions, transaction costs or mark-ups that are more than that which another broker might have charged for effecting the same transaction, in recognition of the value of the brokerage and/or research services provided by the broker. This practice is commonly referred to as "soft dollars" and is permissible under Section 28(e) of the Securities Exchange Act of 1934, so long as certain conditions are met. In some cases, the research provided by Research Brokers is not utilized by Chandler and in other cases, it can be used in servicing any or all of our clients. In other words, there can be certain client accounts that benefit from the research services, which did not make the payment of commissions, transaction costs or mark-ups to the Approved Broker providing the services. This is allowed under Section 28(e); however, the receipt of brokerage and research services from any broker executing transactions for our clients will not result in a reduction of our customary and normal research activities. Also, the receipt of this type of research can be deemed to be the receipt of an economic benefit by us, and although customary, creates a conflict of interest between Chandler and our clients. Therefore, we are providing these disclosures as we believe clients should understand the issues surrounding soft dollars. In addition, we only place trades where we feel best execution can be obtained, taking into consideration all factors surrounding the transaction and not just research received. ITEM 12A.2: BROKERAGE FOR CLIENT REFERRALS Chandler does not direct brokerage in exchange for client referrals. ITEM 12A.3: DIRECTED BROKERAGE Chandler's policy and practice is not to accept advisory clients' instructions for directing client's brokerage transactions, however from time to time, Chandler accepts written direction from a client regarding the use of a particular broker -dealer to execute some or all transactions for the client's account(s). In these circumstances, Page 21 of 26 clients should understand that: (1) we do not negotiate specific brokerage commission rates with the broker on client's behalf, or may not seek better execution services or prices from other broker/dealers and, as a result, the client may pay higher commissions and/or receive less favorable net prices on transactions for their account than might otherwise be the case; (2) transactions for that account generally will be effected independently unless we decide to purchase or sell the same security for several clients at approximately the same time (block trade), in which case we may be able to include such client's transaction with that of other clients for execution if at the same broker; and (3) conflicts may arise between the client's interest in receiving best execution with respect to transactions effected for the account and Chandler's interest in receiving future client referrals from that broker. Therefore, prior to directing us to use a specific broker -dealer, clients should consider whether, under that restriction, execution, clearance and settlement capabilities, commission expenses and whatever amount is allocated to custodian fees, if applicable, would be comparable to those otherwise obtainable. Clients should understand that they might not obtain commissions rates as low as might otherwise be obtain if we had discretion to select other broker -dealers. ITEM 12B: AGGREGATING CLIENT TRADES Order aggregation is the process of adding together or "blocking" orders to purchase and sell the same security as one large order. Chandler will aggregate or "block" trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts and in some cases, employees, and other proprietary accounts so long as transaction costs are shared equally and on a pro -rata (or other fair and reasonable) basis between all accounts included in any such block. Block trading may allow us to execute trades in a timelier, more equitable manner, at a better overall price. Chandler will aggregate trades for itself or for its associated persons with client trades, providing that the following conditions are met: 1) Chandler's policies for the aggregation of transactions shall be fully disclosed in this Form ADV Part 2A and separately to Chandler's existing clients (if any) and the broker-dealer(s) through which such transactions will be placed; 2) We will not aggregate transactions unless aggregation is consistent with our duty to seek best execution and the terms of Chandler's investment advisory agreement with each client for which trades are being aggregated; 3) No participating account will be favored over any other account; each account that participates in an aggregated order will participate at the average price for all the aggregated order, with transaction costs shared pro -rata, when applicable, on each account's participation in the transaction; 4) Chandler will enter aggregated orders into our Order Management System ("OMS"), specifying the participating accounts and how we intend to allocate the order among those accounts; 5) If the aggregated order is filled in its entirety, it will be allocated among participating accounts in accordance with the allocations entered into the OMS; if the order is partially filled, it will be allocated pro -rata based on the allocations entered into the OMS; 6) If the security is purchased from multiple dealers at different prices and is to be allocated among multiple accounts, it will be allocated using a weighted average method; 7) Allocations for an aggregated order should constitute no less than 0.50 of 1% (50 basis points) of a selected portfolio. If a proposed allocation would amount to less than 0.50 of 1% (50 basis points) of the selected portfolio, it may be allocated to a more appropriate account different from that specified in the OMS as long as all client accounts receive fair and equitable treatment and the reason for the different allocation is explained in a manner consistent with the procedures listed in number 8 herein; 8) Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the OMS if all client accounts receive fair and equitable treatment and the reason for the different allocation is explained in writing and is approved in writing by appropriate supervisory personnel no later than one hour after the opening of the markets on the trading day following the day the order was executed; 9) Chandler will receive no additional compensation of any kind as a result of the proposed aggregation; Page 22 of 26 10) Individual investment advice and treatment will be accorded to each advisory client. 11) Chandler's books and records will separately reflect, for each client account, the orders of which are aggregated, the securities held by, and bought and sold for that account. 12) Funds and securities for aggregated orders are clearly identified on Chandler's records and to the broker -dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. There are times when Chandler does not aggregate trades when we have an opportunity to do so. Portfolio managers choose not to aggregate trades in the following situations: Non -discretionary clients: An advisory client electing not to grant investment discretionary authority to Chandler is advised that trades done in his/her account may be executed after trades effected in discretionary accounts due to the additional time involved in obtaining the required client approval prior to executing any trade in such non -discretionary client accounts. Consequently, we may not be able to aggregate these trades with other discretionary trades which may result in a difference in the price per share/bond of a given security and the commission rates paid. Client direction: While rare, an advisory client may choose not to have their trades aggregated or may have cash flow needs that prevent Chandler from aggregating a trade with other pending orders. Consequently, we may not be able to aggregate these client trades with other client trades which may result in a difference in the price per share/bond of a given security and the commission rates paid. Portfolio Manager's discretion: Portfolio managers may choose to trade certain strategies at the same time while waiting to trade others. The timing of the trades and determination of which strategy to trade is dependent on market conditions. Additionally, not all portfolio managers will trade their client accounts at the same time and there may be timing differences for trades executed by different portfolio managers. Accordingly, we may not be able to aggregate all trades executed independently by our different portfolio managers, which may result in a difference in the price per share/bond of a given security and the commission rates paid. 1TEM 13 CQUNT REVI WS ITEM 13A: PERIODIC ACCOUNT REVIEWS FIXED INCOME & MULTI ASSET CLASS PORTFOLIO MANAGEMENT The underlying securities within client accounts are continually monitored and reviewed daily in our Order Management and Portfolio Compliance System (OMS) in the context of each client's stated investment objectives and guidelines. Additional reviews may be triggered by material changes in variables such as the client's individual circumstances, liquidity requirements, credit analysis or the market, political or economic environment. These accounts are reviewed by our Co -Chief Investment Officers, Portfolio Managers and our compliance department. WRAP FEE PROGRAMS Program clients should refer to the selected Sponsor's Wrap Fee Program Brochure and, if applicable, the independent advisor's disclosure document for information regarding reviews performed by the sponsor or independent advisor and the frequency of reviews conducted on the client's Program account(s). CONSULTING SERVICES While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Consulting Services clients unless otherwise contracted for. Page 23 of 26 Such reviews will be conducted by the client's account representative. ITEM 13B: OTHER REVIEWS Chandler reviews accounts on a periodic basis as described above in Item 13A of this brochure. ITEM 13C: REPORTING FIXED INCOME & MULTI ASSET CLASS PORTFOLIO MANAGMENT In addition to the monthly account statements that non -wrap clients receive from their custodian and confirmations of transactions that they receive from the executing broker -dealer, we provide written monthly reports summarizing account performance, balances and holdings, transactions, income earned, and cash flow expected for the next 365 days. WRAP FEE PROGRAMS Program clients should refer to the selected Sponsor's Wrap Fee Program Brochure and, if applicable, the independent advisor's disclosure document for information regarding the content and frequency of reports provided by the sponsor or independent advisor to the client, if any. Chandler does not send any reports or account statements to wrap fee program clients. CONSULTING SERVICES These client accounts will receive written reports as contracted for at the inception of the advisory engagement. ITEM 14A: OTHER COMPENSATION As outlined in Item 12A of this Brochure, certain indirect economic benefits are received by Chandler for clients that custody their assets with Schwab. While Chandler and its employees always endeavor to put the interest of our clients first, clients participating in the Schwab wrap programs should be aware that receipt of this indirect additional compensation creates a potential conflict of interest. However, Chandler has a fiduciary responsibility to always place client interests before our own and will only recommend Schwab to clients where we believe it would be beneficial to those clients. ITEM 14B: CLIENT REFERRALS Chandler's policy and practice is not to enter into arrangements to pay referral fees to independent persons or firms ("Solicitors") for introducing clients to us. Compensation paid to certain related persons of Chandler takes into consideration an overall assessment of predetermined objectives in addition to other defined criteria. Notably, this firm practice does not impact the advisory fees paid to Chandler by any client. Chandler does not take custody or possession of the funds or securities that a client has placed under our management. Each client shall appoint a Qualified Custodian ("custodian") to take and have possession of their assets. The fees expressed in the "Fees and Compensation" section (Item 5A) of this Brochure do not include fees a client will incur for custodial services. From time to time, Chandler recommends a custodian to clients who do not have an existing custodian relationship established. Among others, Chandler generally recommends (in alphabetical order) Bank of America, Bank of New York/Mellon, Charles Schwab & Co., Union Bank, US Bank or Wells Fargo. Some of the above -mentioned custodians offer special pricing for institutional or municipal clients of Chandler. Chandler does not receive any compensation or referrals from the custodians we refer our clients to. The rates offered by the Page 24 of 26 custodian can be based on the size of the portfolio or type of account opened. Client retains full discretionary authority over the selection of the custodian to be used. Direct Debiting of Fees Although Chandler does not take custody or possession of the funds or securities that a client has placed under its management, Chandler is deemed by the SEC to have custody of those accounts where fees are debited directly from the client's custodian bank account. We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions and holdings within the account during the reporting period, in addition to any advisory fees paid. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. In addition to the periodic statements that clients receive directly from their custodians, we also send account statements directly to our clients monthly. While Chandler makes every effort to provide accurate statements, we urge our clients to carefully compare the information provided on our statements to statements provided by their custodian in order to ensure that all account transactions, holdings and values are correct and current. I ITEM 16 l'ESTNIENT DISCRETION Generally, clients hire us to provide discretionary asset management services; however, we do provide our services on a non -discretionary basis, if requested by a client. Our discretionary authority includes the ability to do the following without first obtaining approval from the client ■ Determine the security to buy or sell; • Determine the amount of the security to buy or sell; and • Determine the price at which to buy or sell the security; Clients give us discretionary authority when they sign a discretionary client agreement with our firm and may limit this authority by giving us written instructions. Such limitations are typically outlined in a client's investment policy statement and may include restrictions on maturity or ratings, issuer or sector concentration limitations, among others. Clients may also change/amend such limitations by once again providing us with written instructions. Chandler reserves the right to decline acceptance of any client account. 17 • TING•CLIENT SECURITIES ITEM 17A: PROXY VOTING We vote proxies for the securities held in client accounts where the client has given us authorization to do so. All clients retain the right to vote their own proxies should they choose to do so. Clients can exercise this right by instructing us in writing to not vote proxies in their account and instructing their custodian to send proxies directly to their attention. We will vote proxies in the best interests of our clients and in accordance with our established policies and procedures. Our firm will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, a copy of any document created by us that was material to making a decision how to vote proxies, and a copy of each written client request for information on how the adviser voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify the client of the conflict and retain an independent third -party to cast a vote. Clients may obtain a copy of our complete proxy voting policies and procedures by contacting Joseph Kolinsky, our Chief Compliance Officer, by telephone, email, or in writing. Clients may request, in writing, information on how proxies for their shares were voted. If any client requests a copy of our complete proxy policies and Page 25 of 26 procedures or how we voted proxies for their account(s), we will promptly provide such information to the client. We will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client's account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor's right to vote proxies. To direct us to vote a proxy in a particular manner, clients should contact Joseph Kolinsky by telephone, email, or in writing. You can instruct us to vote proxies according to criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so-called "poison pill" defense against a possible takeover). You can also instruct us on how to cast your vote in a particular proxy contest by contacting Joseph Kolinsky by mail at 6225 Lusk Boulevard, San Diego, CA 92121 or by email at Compliance@chandlerasset.com. These requests must be made in writing. ITEM 17B: WHERE CLIENT RETAINS RIGHT TO VOTE PROXIES For accounts where we do not vote proxies, Chandler may provide investment advisory services relative to client investment assets. 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; and 3) Instructing each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client's investment assets. We may provide clients with consulting assistance regarding proxy issues if they contact us with questions at our principal place of business. IITEM18 FINANCIAL INFORMATION ITEM 18A: FINANCIAL STATEMENT REQUIREMENT Under no circumstances do we require or solicit payment of fees in excess of $1200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. ITEM 18B: FINANCIAL CONDITION Chandler has no financial conditions to disclose that would impair its ability to meet contractual and fiduciary obligations to clients. ITEM 18C: BANKRUPTCY DISCLOSURE Chandler has never been the subject of a bankruptcy petition. Page 26 of 26 Rev [01/2014] FACTS WHAT DOES CHANDLER ASSET MANAGEMENT, INC. DO WITH YOUR PERSONAL INFORMATION? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Social Security number and investment experience • Account balances and transaction history • Assets and income When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Chandler chooses to share; and whether you can limit this sharing. For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus For our marketing purposes - to offer our products and services to you For joint marketing with other financial companies For our affiliates' everyday business purposes - information about your transactions and experiences For our affiliates' everyday business purposes - information about your creditworthiness For our affiliates to market to you For non -affiliates to market to you Yes Yes No No No No No Call (858) 546-3737 or go to www.chandlerasset.com No No We do not share We do not share We do not share We do not share We do not share Page 2 CHANDLER ASSET MANAGEMENT, INC. How does Chandler protect my personal To protect your personal information from unauthorized access information? and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. How does Chandler collect my personal We collect your personal information, for example, when you information? Why can't I limit all sharing? ■ Open an account or enter into an investment advisory agreement ■ Give us your income information and your contact information ■ Tell us about your investment or retirement portfolio We also collect your personal information from other companies Federal law gives you the right to limit only ■ sharing for affiliates' everyday business purposes information about your creditworthiness ■ affiliates from using your information to market to you ■ sharing for non -affiliates to market to you State laws and individual companies may give you additional rights to limit sharing. [See below for more on your rights under state law.] Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies. ■ Chandler Asset Management, Inc. has no affiliates. Non -affiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies. ■ Chandler Asset Management, Inc. does not share with non -affiliates so they can market to you Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. ■ Chandler Asset Management, Inc. doesn't jointly market. Information for Vermont, California and Nevada Customers In response to a Vermont regulation, if we disclose personal information about you to non-affiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transactions or experiences with you. In response to a California law, we automatically treat accounts with California billing addresses as if you do not want to disclose personal information about you to non-affiliated third parties except as permitted by the applicable California law. We will also limit the sharing of personal information about you with affiliates to comply with all California privacy laws that apply to us. Nevada law requires us to disclose that you may request to be placed on our "do not call" list at any time by calling 1- 831-759-6300. To obtain further information, contact the Bureau of Consumer Protection, Office of the Nevada Attorney General at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 88101; phone 1-702-486-3132; email BCPINFO@ag.state.nv.us CAIICHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 Martin Cassell, CFA CEO Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about Martin Cassell that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Martin Cassell is available on the SEC's website www.adviserinfo.sec.gov. 1 ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Martin Dayle Cassell 1959 California State University Hayward; BS, Finance; 1987 01/2022 to Present: CEO — Chandler Asset Management Inc. 2008 to Present: CEO, Chief Investment Officer & Principal — Chandler Asset Management, Inc. 2003 to 2008: Chief Investment Officer & Principal — Chandler Asset Management, Inc. 1993 to 2003: VP, Portfolio Manager & Principal — Chandler Asset Management, Inc. 1991 to 1993: Portfolio Manager — Chandler Asset Management, Inc. Chartered Financial Analyst (CFA); CFA Institute; 1998 For an explanation of the CFA designation, please see page 10 ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Martin Cassell. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Martin Cassell sits on the Investment Committee for the San Diego Foundation and is on the Board of Trustees and Finance Committee for the San Diego Botanic Garden. Mr. Cassell devotes approximately 2-5 hours a month to these activit i es Martin Cassell does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Martin Cassell is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. ITEM 5: ADDITIONAL COMPENSATION Martin Cassell does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Board of Directors (858) 546-3737 CM _ www.chandlerasset.com Page 1 CA%CHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 ITEM 1: COVER PAGE William Dennehy II, CFA Co- Chief investment Officer Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about William Dennehy ll that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about William Dennehy ll is available on the SEC's website at www.adviserinfo.sec.gov. ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: William Dennehy II 1970 California State University Chico; BS, Business/Finance; 1992 01/2022 to Present: Co -Chief Investment Officer — Chandler Asset Management Inc. 06/2020 to 2021: Deputy Chief Investment Officer — Chandler Asset Management, Inc. 2016 to 2020: EVP, Portfolio Manager — Chandler Asset Management, Inc. 2012 to 2015: SVP, Portfolio Manager — Chandler Asset Management, Inc. 2011 to 2012: VP, Portfolio Manager — Chandler Asset Management, Inc. 2001 to 3/2011: Senior Portfolio Manager — Northern Trust Global Investments Chartered Financial Analyst (CFA); CFA Institute; 2000 For an explanation of the CFA designation, please see page 10 ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of William Dennehy II. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities William Dennehy II is not engaged in any other investment -related activities. William Dennehy II does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities William Dennehy II is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. ITEM 5: ADDITIONAL COMPENSATION William Dennehy II does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Martin Cassell CEO (858) 546-3737 CM www.chandlerasset.com Page 2 CAIICHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 Scott Prickett, CTP Co- Chief Investment Officer Chandler Asset Management, Inc. 801 2nd Avenue, Suite 800 Seattle, WA 98104 (800) 317-4747 Chandler Asset Management, Inc. 1875 Lawrence Street, Suite 920 Denver, CO 80202 (800) 317-4747 This brochure supplement provides information about Scott Prickett that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that- brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Scott Prickett is available on the SEC's website at www.adviserinfo.sec.qov. • a11, - ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Scott David Prickett 1963 University of Northern Colorado; BS, Business Finance; 1987 01/2022 to Present: Co -Chief Investment Officer — Chandler Asset Management Inc. 06/2020 to 2021: Co- Chief Investment Officer — Chandler Asset Management, Inc. 01/2016 to 05/2020: EVP, Portfolio Strategist — Chandler Asset Management, Inc. 04/2014 to 12/2015: SVP, Portfolio Strategist — Chandler Asset Management, Inc. 05/2006 to 04/2014: SVP, Managing Director, Portfolio Manager — Davidson Fixed Income Mgmt. Inc. 05/2006 to 04/2014: SVP, Managing Director - D.A. Davidson& Co. Certified Treasury Professional (CTP); Association of Financial Professionals; 2000 For an explanation of the CTP designation, please see page 10 ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Scott Prickett. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Scott Prickett is not engaged in any other investment -related activities. Scott Prickett does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Scott Prickett is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. ITEM 5: ADDITIONAL COMPENSATION Scott Prickett does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Martin Cassell CEO (858) 546-3737 www.chandlerasset.com Page 3 CAIICHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 Jayson Schmitt, CFA Co- Chief Investment Officer Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about Jayson Schmitt that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Jayson Schmitt is available on the SEC's website at www. adviserin fo.sec. qov. ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Jayson Arnold Schmitt 1969 California State University San Diego; BA, Economics; 1995 01/2022 to Present: Co -Chief Investment Officer — Chandler Asset Management Inc. 06/2020 to 2021: Deputy Chief Investment Officer — Chandler Asset Management, Inc. 2016 to 2020: EVP, Portfolio Manager & Principal — Chandler Asset Management, Inc. 2010 to 2015: SVP, Portfolio Manager & Principal — Chandler Asset Management, Inc. 2009 to 2010: VP, Portfolio Manager & Principal — Chandler Asset Management, Inc. 2003 to 2009: VP, Portfolio Manager — Chandler Asset Management, Inc. Chartered Financial Analyst (CFA); CFA Institute; 2003 For an explanation of the CFA designation, please see page 10 ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Jayson Schmitt. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Jayson Schmitt is not engaged in any other investment -related activities. Jayson Schmitt does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Jayson Schmitt is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. ITEM 5: ADDITIONAL COMPENSATION Jayson Schmitt does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Martin Cassell CEO (858) 546-3737 www.chandlerasset.com Page 4 CA%CHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 Daniel Delaney, CFA Senior Portfolio Manager Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about Daniel Delaney that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Daniel Delaney is available on the SEC's website at www.adviserinfo.sec.gov. ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Daniel Joseph Delaney 1981 University of Exeter, UK April 2021 to Present: Senior Portfolio Marager — Chandler Asset Management, Inc. January 2017 to April 2021: Director / Senior Portfolio Manager — Allianz Global Investors April 2006 — December 2016: Global Credit Analyst / Portfolio Manager — Rogge Global Partners Chartered Financial Analyst (CFA); CFA Institute; 2010 For an explanation of the CFA designation, please see page 10 ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Daniel Delaney. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Daniel Delaney is not engaged in any other investment -related activities. Daniel Delaney does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Daniel Delaney is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of her time. ITEM 5: ADDITIONAL COMPENSATION Daniel Delaney does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: William Dennehy II Co -Chief Investment Officer (858) 546-3737 www.chandlerasset.com Page 5 CA%CHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 ITEM 1: COVER PAGE Julie Hughes Senior Portfolio Strategis Chandler Asset Management, Inc. 1875 Lawrence Street, Suite 920 Denver, CO 80202 (800) 317-4747 This brochure supplement provides information about Julie Hughes that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Julie Hughes is available on the SEC's website at www.adviserinfo.sec.qov. ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Julie Kirschner Hughes 1964 University of Texas at Austin; BBA, Marketing; 1986 The Wharton School of the University of Pennsylvania; MBA, Entrepreneurial Management; 1992 06/2020 to Present: Senior Portfolio Strategist — Chandler Asset Management, Inc. 01/2016 to 05/2020: SVP, Portfolio Strategist — Chandler Asset Management, Inc. 04/2014 to 12/2015: VP, Portfolio Strategist — Chandler Asset Management, Inc. 08/2007 to 04/2014: SVP, Portfolio Manager — Davidson Fixed Income Management None ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Julie Hughes. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. B. Investment -Related Activities Julie Hughes is not engaged in any other investment -related activities. Julie Hughes dces not receive commissions, bonuses or other compensation on the sale of securities or other investment products. Non -Investment -Related Activities Julie Hughes is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of her time. ITEM 5: ADDITIONAL COMPENSATION Julie Hughes does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Scott Prickett Co -Chief Investment Officer (800) 317-4747 PCM www.chandlerasset.com Page 6 CA%CHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 Genny Lynkiewicz, CFA Senior Portfolio Manager Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about Genny Lynkiewicz that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Genny Lynkiewicz is available on the SEC's website at www.adviserinfo.sec.qov. ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Genevieve Cathryn Lynkiewicz 1974 University of Wisconsin, Madison; BBA, Finance, Investment & Banking; 1997 06/2020 to Present: Senior Portfolio Manager — Chandler Asset Management, Inc. 10/2015 to 05/2020: VP, Portfolio Manager — Chandler Asset Management, Inc. 08/2012 to 02/2015: VP, Fixed Income Portfolio Manager — BMO Asset Management Corp. 02/2012 to 08/2012: Fixed Income Portfolio Manager — M&I Investment Management Corp. Chartered Financial Analyst (CFA); CFA Institute; 2006 For an explanation of the CFA designation, please see page 10 ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Genny Lynkiewicz. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Genny Lynkiewicz serves as the CFO/Treasurer for the San Diego Peace Corps Association. Ms. Lynkiewicz devotes approximately 4-5 hours a month to this activity. Genny Lynkiewicz does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Genny Lynkiewicz is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of her time. ITEM 5: ADDITIONAL COMPENSATION Genny Lynkiewicz does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Jayson Schmitt Co -Chief Investment Officer (858) 546-3737 cM www.chandlerasset.com Page 7 CMCHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 ITEM 1: COVER PAGE Carlos Oblites Senior Portfolio Strategist Chandler Asset Management, Inc. 7250 Redwood Boulevard, Suite 300 Novato, CA 94945 (800) 317-4747 This brochure supplement provides information about Carlos Oblites that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information abcut Carlos Oblites is available on the SEC's website at www.adviserinfo.sec.qov. 44 • iipts ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Carlos Oblites 1969 University of CA, Santa Barbara; BA, History; 1990 San Francisco State University; MBA; 2003 06/2020 to Present: Senior Portfolio Strategist — Chandler Asset Management, Inc. 01/2017 to 05/2020: SVP, Portfolio Strategist — Chandler Asset Management, Inc. 09/2015 to 01/2017: Administrative Services Manager — Central Marin Sanitation Agency 05/2007 to 09/2015: Director — PFM Asset Management None ITEM 3: DISCIPLINARY INFOR1VIATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Carlos Oblites. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Carlos Oblites is not engaged in any other investment -related activities. Carlos Oblites does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Carlos Oblites not engaged in any other business or occupation that provides substantial compensation or involves a substantial amcunt of his time. ITEM 5: ADDITIONAL COMPENSATION Carlos Oblites does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Scott Prickett Co -Chief Investment Officer (800) 317-4747 [-CM www.chandlerasset.com Page 8 CAtHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 ITEM 1: COVER PAGE Ted Piorkowski, CFA Senior Portfolio Manager Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about Ted Piorkowski that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Ted Piorkowski is available on the SEC's website at www.adviserinfo.sec.gov7- _ ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Theodore James Piorkowski 1959 California State University San Diego; BS, Finance; 1982 California State University San Diego; MBA, Finance; 1985 2009 — Present: Senior Portfolio Manager & Principal — Chandler Asset Management, Inc. 2004 to 2009: SVP, Portfolio Manager — Chandler Asset Management, Inc. 1999 to 2004: VP, Portfolio Manager — Chandler Asset Management, Inc. 1994 to 1999; VP, Fund Manager — Sefton Capital Management, Inc. Chartered Financial Analyst (CFA); CFA Institute; 1991 For an explanation of the CFA designation, please see page 10 ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Ted Piorkowski. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Ted Piorkowski is not engaged in any other investment -related activities. Ted Piorkowski does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Ted Piorkowski is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. ITEM 5: ADDITIONAL COMPENSATION Ted Piorkowski does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Jayson Schmitt Co -Chief Investment Officer (858) 546-3737 kit www.chandlerasset.com Page 9 CMCHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 ITEM 1: COVER PAGE Alayne Marie Sampson Senior Portfolio Strategist Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about Alayne Marie Sampson that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. r Additional information about Alayne Marie Sampson is available on the SEC's website at www.adviserinfo.sec.qov. ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Alayne Marie Sampson 1977 Cornell University, B.A., 2000 04/2022 to Present: Senior Portfolio Strategist — Chandler Asset Management Inc. 02/2002 - 04/2022: Credit Analyst — Capital Group None ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Alayne Marie Sampson. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Alayne Marie SE mpson is not engaged in any other investment -related activities Alayne Marie Sampson does not receive commissions, bonuses or other compensation on the sale of securities or other investment prcducts. B. Non -Investment -Related Activities Alayne Marie Sampson is engaged in an other business or occupation that does not provide substantial compensation or involves a substantial amount of her time. Alayne Marie Sampson is the Vice Chair of the Board, as well as the Chair of the Finance Committee / Treasurer of Court Appointed Special Advocates (CASA) of Los Angeles. Alayne Marie Sampson provides oversight and certification of the financial statements and renders an account of transactions and financial conditions of CASA Los Angeles to the Board. ITEM 5: ADDITIONAL COMPENSATION Alayne Marie Sampson does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Scott Prickett Co -CIO 800-317-4747 www.chandlerasset.com Page 10 CA%CHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 Karl Meng Portfolio Strategist Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about Karl Meng that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Koiinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Karl Meng is available on the SEC's website at www.adviserinfo.sec.qov. eft ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Karl Otto Meng 1983 San Diego State University, BA, 2008 07/2022 to Present: Portfolio Strategist — Chandler Asset Management Inc. 01/2012 - 05/2022: Institutional Sales & Trading — Vining Sparks IBG, LP 07/2008 - 06/2011: Institutional Sales & Trading — Stone & Youngberg LLC 08/2006 - 06/2007: Associate — NYLIFE Securities LLC None ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Karl Meng. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Karl Meng is not engaged in any other investment -related activities Karl Meng does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Karl Meng is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. ITEM 5: ADDITIONAL COMPENSATION Karl Meng does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Scott Prickett Co -CIO 800-317-4747 rat www.chandlerasset.com Page 11 CAIICHANDLER ASSET MANAGEMENT Part 2B of Form ADV: Brochure Supplement Effective Date: October 12, 2022 ITEM 1: COVER PAGE Kara Raynor -Sanchez Associate Portfolio Strategist Chandler Asset Management, Inc. 6225 Lusk Boulevard San Diego, CA 92121 (800) 317-4747 This brochure supplement provides information about Kara Raynor -Sanchez that supplements the Chandler Asset Management (Chandler) brochure. You should have received a copy of that brochure. Please contact Joseph Kolinsky if you did not receive Chandler's brochure or if you have any questions about the contents of this supplement. Additional information about Kara Raynor -Sanchez is available on the SEC's website at www.adviserinfo.sec.qov. ITEM 2: EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE Full Legal Name: Year of Birth: Post High School Education: Business Background: Professional Designations: Kara Lee Raynor -Sanchez 1986 University of Pacific, BA, 2013 San Diego State University, MA, 20 08/2022 to Present: Associate Portfolio Strategist — Chandler Asset Management Inc 05/2019 to 07/2022: Client Service Director — Chandler Asset Management Inc. 05/2013 to 04/2019: Client Service Associate — Chandler Asset Management Inc. 05/2012 to 04/2013: Administrative Assistant — Chandler Asset Management Inc. 03/2012 to 04/2012: Administrative Assistant — The Lawton Group None • ITEM 3: DISCIPLINARY INFORMATION Chandler is required to disclose all material facts regarding any legal or disciplinary events that would materially impact a client's evaluation of Kara Raynor -Sanchez. No events have occurred that are applicable to this item. ITEM 4: OTHER BUSINESS ACTIVITIES Chandler is required to disclose any outside business activities or occupation for compensation that could potentially create a conflict of interest with clients. A. Investment -Related Activities Kara Raynor -Sanchez is not engaged in any other investment -related activities Kara Raynor -Sanchez does not receive commissions, bonuses or other compensation on the sale of securities or other investment products. B. Non -Investment -Related Activities Kara Raynor -Sanchez is not engaged in any other business or occupation that provides substantial compensation or involves a substantial amount of his time. ITEM 5: ADDITIONAL COMPENSATION Kara Raynor -Sanchez does not receive any economic benefit from a non -advisory client for the provision of advisory services. ITEM 6: SUPERVISION Supervisor: Title: Phone Number: Scott Prickett Co -CIO 800-317-4747 www.chandlerasset.com Page 12 CA% CHANDLER ASSET MANAGEMENT ('Professional p`esignatiohs'Held CFA Charter The Chartered Financial Analyst (CFA) charter is a globally respected, graduate -level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals There are currently more than 100,000 CFA charterholders working throughout the world To earn the CFA charter, candidates must 1) pass three sequential, six -hour examinations, 2) have at least four years of qualified professional investment experience, 3) loin CFA Institute as members, and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct High Ethical Standards The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to • Place their clients' interests ahead of their own • Maintain independence and objectivity • Act with integrity • Maintain and improve their professional competence • Disclose conflicts of interest and legal matters Global Recognition Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates report spending an average of 300 hours of study per level) Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today's quickly evolving global financial industry Asa result, employers and clients are increasingly seeking CFA charterholders—often making the charter a prerequisite for employment Additionally, regulatory bodies in 19 countries recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own finance courses Comprehensive and Current Knowledge The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession The three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed -income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to reflect the dynamic and complex nature of the profession To learn more about the CFA charter, visit www cfainstitute org Certified Treasury Professional (CTP) The Certified Treasury Professional ® (CTP) designation is evidence that an individual is certified in corporate treasury and cash management The credential is awarded based upon experience and passing of a rigorous examination that provides an objective measure of an individual's broad -based knowledge and competency in treasury management Ongoing professional development is required in order to maintain the credential The CTP is administered by the Association for Financial Professionals, the leading association for treasury and financial management professionals, with more than 29,000 members worldwide Accredited Investment Fiduciary (AIF®) The Accredited Investment Fiduciary (AIF®) Designation is a professional certification that demonstrates an advisor or other person serving as an investment fiduciary has met certain requirements to earn and maintain the credential The purpose of the Accredited Investment Fiduciary (AIF®) Designation is to assure that those responsible for managing or advising on investor assets have a fundamental understanding of the principles of fiduciary duty, the standards of conduct for acting as a fiduciary, and a process for carrying out fiduciary responsibility Initial certification requires completion of AIF® training, passing of the AIF® examination, meeting the education and industry experience requirements, and satisfaction of the Code of Ethics and Conduct Standards To maintain the designation, designees must complete six (6) hours of continuing education and satisfy the Code of Ethics and Conduct Standards annually The AIF® is administered by the Center for Fiduciary Studies Appendix AL!C 1 Chandler rofessional iographies CAI Investment Management Martin Cassell, CFA CEO Martin Cassell is the Chief Executive Officer at Chandler Asset Management and is a principal of the firm. He is responsible for defining, planning, and directing company programs. Martin heads implementation of the firm's investment strategies and portfolio risk management. He designed the proprietary quantitative models that drive our investment process, establishing duration, structure, and asset allocation throughout client portfolios. Martin joined Chandler in 1991 from the City of San Diego where he managed a $1 billion fixed income portfolio. He began his investment career in 1987 managing portfolios at World Savings and Loan. Martin received his B.S. in finance from California State University, Hayward. He is a member of the CFA Society of San Diego and holds the designation of Chartered Financial Analyst. Martin is also a member of the Government Finance Officers Association (GFOA) Treasury and Investment Committee (TIM) and the California Association of Joint Power Authorities (CAJPA) finance committee. William Dennehy II, CFA Co -Chief Investment Officer 1, Prior to joining Chandler in 2011, Bill worked at Northern Trust Global Investments in Chicago, most recently as senior portfolio manager and vice president, with a wide range of responsibilities in asset allocation, quantitative and qualitative analysis. Bill earned his B.S. in business administration, option in finance, at California State University, Chico. He holds the designation of Chartered Financial Analyst. William Dennehy is Co -Chief Investment Officer at Chandler Asset Management. He is responsible for implementing portfolio strategy and securities trading in client accounts and serves as Co -Chair of the firm's Economic and Market Analysis Committee and Credit Committee. Scott Prickett, CTP Co -Chief Investment Officer I • Scott Prickett is Co -Chief Investment Officer. He is responsible for building and maintaining client relationships with a focus upon developing and enhancing client investment programs. Scott actively participates in the portfolio management process and meets with clients on a regular basis to review their accounts, portfolio activity, portfolio strategy and financial markets. Scott has over 30 years of investment industry experience focused largely on managing short-term fixed income strategies for governmental and institutional non-profit clients. Scott serves as Co -Chair of the firm's Economic and Market Analysis Committee. Prior to joining Chandler, Scott was Managing Director and Portfolio Manager at Davidson Fixed Income Management. Scott was directly responsible for managing over $750 million in client assets and had management responsibilities over multiple business units with combined total assets of over $5 billion. These included taxable and tax-exempt SMA programs, a Local Government Investment Pool (LGIP) and SeaCap Investment Advisors. At 1en ALPS Mutual Fund Services, Scott played a key role in developing two SEC registered mutual funds. Scott also spent two years at Pacific Investment Management Company (PIMCO) as a fixed income Portfolio Specialist for over $1.4 billion in assets. Scott is a graduate of the University of Northern Colorado with a degree in business administration with an emphasis in finance. Scott has earned the Association of Financial Professionals designation as a Certified Treasury Professional (CTP) and is a frequent speaker for various local and national organizations. Jayson Schmitt, CFA Co -Chief Investment Officer Jayson Schmitt is Co -Chief Investment Officer. Jayson is instrumental in the development and integration of quantitative analytic tools for the portfolio management process and provides full- time oversight of the entire investment management team and the implementation of the firm's strategies. He serves on the firm's Executive Committee, as well as Co -Chair of the Quantitative Analysis Committee, Sector Committee, and Multi Asset Class Committee. Prior to joining Chandler in 1995, Jayson was employed as a Financial Analyst with USA Federal Credit Union in San Diego, managing a $100 million liquidity book. His responsibilities there also included asset/liability management. Jayson earned his B.A. in economics from San Diego State University. He is a member of the CFA Society of San Diego and holds the designation of Chartered Financial Analyst. Jayson also is a member of the City of San Diego Investment Advisory Committee. The committee assists the City with its investment program by providing regular policy and portfolio reviews. Daniel Delaney, CFA Senior Portfolio Manager Daniel (Dan) Delaney is Senior Portfolio Manager at Chandler Asset Management. He is responsible for implementing portfolio strategy and securities trading in client accounts. Prior to joining Chandler in 2021, Dan was a Senior Portfolio Manager with Allianz Global Investors, based in New York, responsible for managing Global Credit mandates. Dan also spent ten years as a Global Credit Analyst and Portfolio Manager with Rogge Global Partners, both in London and New York. Daniel earned a Bachelor of Arts (Honors) degree in Business Economics from the University of Exeter, UK. He holds the designation of Chartered Financial Analyst. Julie Hughes Senior Portfolio Strategist Julie Hughes is Senior Portfolio Strategist at Chandler Asset Management. She is responsible for building and maintaining client relationships with public agencies along with participating actively in the portfolio management process. Julie has over 25 years of finance, strategy, and client relationship management experience. Prior to joining Chandler, Julie was a Portfolio Manager at Davidson Fixed Income Management, where she managed short-term fixed income portfolios for government and non-profit clients. Julie also has deep expertise in the investment of tax-exempt bond proceeds and hedging interest rate risk for municipal debt. Prior to 2004, she held positions in corporate strategy and management consulting. Julie earned an MBA from the Wharton School of the University of Pennsylvania and a BBA in Marketing from the University of Texas of Austin. Genny Lynkiewicz, CFA Senior Portfolio Manager Genny Lynkiewicz is Senior Portfolio Manager at Chandler Asset Management. She is responsible for implementing portfolio strategy and securities trading in client accounts, and currently serves as Co -Chair of the firm's Sector Committee. Prior to joining Chandler in 2015, Genny worked at BMO Asset Management in Chicago where she managed over $8 billion in taxable money market funds, securities lending portfolios and separately managed accounts. Genny earned a B.B.A. in Finance, Investment & Banking and a Certificate in International Business from the University of Wisconsin, Madison. She holds the designation of Chartered Financial Analyst. Carlos Oblites Senior Portfolio Strategist Carlos Oblites is Senior Portfolio Strategist. He is responsible for building and maintaining client relationships with public agencies along with participating actively in the portfolio management process. Carlos has 26 years of investment and financial experience, focused largely on managing short-term fixed income and pension strategies for governmental and institutional non-profit clients. Carlos currently serves as Co -Chair of the firm's Multi Asset Class Committee. He also serves as a member of the Government Finance Officers Association's (GFOA) Committee on Retirement and Benefits Administration (CORBA), which tracks new industry practices, regulatory and legislative developments, and issues best practices to assist public pension and personnel officers effectively manage state and local retirement funds and employee benefits. Prior to joining Chandler, Carlos served as the Administrative Services Manager at Central Marin Sanitation Agency (CMSA) and was responsible for all aspects of the Agency's financial, human resources, administrative support, and information systems activities. He also has significant expertise in serving California public agencies, healthcare, and insurance clients through his roles as Director at PFM Asset Management, and as a Principal at Wells Capital Management. Previous responsibilities include managing a variety of institutional client relationships and developing, implementing, and monitoring customized investment strategies for operating funds, bond proceeds, pension, and post -retirement funds. Carlos has also worked as a teacher for the Long Beach Unified School District. Carlos holds a Bachelor of Arts degree in History from the University of California, Santa Barbara, and earned a master's degree in Business Administration from San Francisco State University. Ted Piorkowski, CFA Senior Portfolio Manager Ted Piorkowski is a Senior Portfolio Manager at Chandler Asset Management. In addition to his duties as a portfolio manager, he oversees daily trading and is responsible for implementing portfolio strategy. Ted leads the Economic and Market Analysis Committee, as well as the Sector Committee. Prior to joining Chandler in 1999, Ted served as a Vice President and Fund Manager for Sefton Capital Management. He was responsible for the management of over $300 million in both mutual fund vehicles and individually managed institutional portfolios. From 1988 through 1994, Ted managed money market and enhanced money market funds for San Diego Trust and Savings Bank and its successor, San Diego Financial Capital Management. Ted earned both his B.S. and M.B.A. in finance from San Diego State University. He is a member of the CFA Society of San Diego and holds the designation of Chartered Financial Analyst. Alayne Marie Sampson Senior Portfolio Strategist Alayne Marie Sampson joined Chandler Asset Management in 2022 as a Senior Portfolio Strategist. She is a member of the Investment Management Team and participates actively in the portfolio management process as well as builds and maintains client relationships. Alayne has over 20 years of investment and financial experience. She focuses on identifying and communicating key investment -related themes and trends for implementation into fixed income strategies for local government and institutional clients. Prior to joining Chandler, Alayne was a Senior Short -Term Credit Analyst, where she was responsible for fundamental credit analysis of commercial paper issuers for a $135 billion cash portfolio. Other roles include Business Project Manager, TAP Associate, and Senior Business Systems Analyst. Alayne is a court -appointed special advocate in Los Angeles and serves as a board member on Finance and Audit committees. She is a Vice Chair of Finance Committee. Alayne is a graduate of Cornell University with her B.A. in Women's Studies in 2000. Karl Meng Portfolio Strategist Karl Meng joined Chandler Asset Management in 2022 as a Portfolio Strategist. He is a member of the Investment Management Team and participates actively in the portfolio management process as well as builds and maintains client relationships. He focuses on identifying and communicating key investment -related themes and trends for implementation into clients' portfolios. Karl has over 14 years of Institutional Sales & Trading experience specializing in Federal Agency Fixed Income products, Mortgage -Backed Securities, and US Treasuries. Prior to joining Chandler, Karl was a Vice President for Vining Sparks IBG LP, where he was responsible for establishing and maintaining trading relationships with Government Entities and Institutional Asset managers. Karl is a graduate of San Diego State University with his B.A. in Economics. He holds the FINRA Series 7 and Series 63 licenses. CAIL Stephen Church Assistant Portfolio Manager n Stephen Church joined Chandler Asset Management in 2022 as an Assistant Portfolio Manager. He is responsible for supporting the investment management team with portfolio and fixed income research as well as assisting with trading and reporting issues. Previously, Stephen worked as an Associate Portfolio Manager at Hearthstone Wealth Management where he provided research on economic and market conditions, trends, asset classes, individual investments, and investment strategies as well as assisted in investment model construction, implementation, management, and maintenance. Prior to working at Hearthstone, he worked at Fisher Investments as a Research Analyst within the Portfolio Evaluation Group. Stephen graduated from the University of Arizona in 2012 with a B.S. in Business Administration. Stephen currently pursuing the Chartered Financial Analyst° designation. Charlotte Powell Associate Portfolio Manager Charlotte Powell is Associate Portfolio Manager at Chandler Asset Management. She is responsible for supporting the investment management team with portfolio and fixed income research as well as assisting with trading and reporting issues. Charlotte joined the firm in 2021. Previously, Charlotte worked as an Investment Analyst at Lingerfelt Commonwealth Partners where she was responsible for asset valuations and analyzing fund performance. Prior to working at Lingerfelt, she spent a summer at Morgan Stanley working on their Institutional Equity Client Coverage team. Charlotte graduated from Virginia Tech in 2019 with B.S. in Finance. While at Virginia Tech, she was a Financial Sector analyst for the Student -managed Endowment for Educational Development, which managed over $5 million of the University's endowment long -only in equities. Charlotte is currently pursuing the Chartered Financial Analyst° designation. Kara Raynor -Sanchez Associate Portfolio Strategist Kara Raynor -Sanchez joined Chandler Asset Management in 2012 and is an Associate Portfolio Strategist. As a member of the Investment Management team, she actively participates in the portfolio management process with a focus on building and maintaining our client relationships. Kara focuses on identifying and communicating key investment -related themes and trends for implementation into local government and institutional client portfolios. Kara held various roles working in administration and client service departments prior to accepting the position of Client Service Director. She graduated with her B.A. in communication, with emphasis in public relations from the University of the Pacific and earned her M.A. in communication from San Diego State University. Kara was awarded the CFA Institute's Investment Foundations Certificate (formerly Claritas° Investment Certificate) in 2013. She holds the FINRA Series 65 license. Relationship Management and Client Service Ben Mendenhall Senior Relationship Manager Ben Mendenhall is a Senior Relationship Manager and joined the firm in 2022 with 16 years of investment management experience. He has worked with the Colorado local governments for over 12 years. Ben maintains existing relationships and develops new ones, and his area of focus is on the development of client relationships in the Rocky Mountain Region. Previously, Ben was a VP of Investment Advisory Services for Public Trust Advisors where he was responsible for relationship management, LGIP development and service, client education, portfolio strategies and reviews. Prior to working for Public Trust Advisors, he worked for Public Financial Management (PFM) as a Senior Analyst, serving in a variety of client facing roles. Ben is a graduate of the University of Rhode Island with a B.S. in Business Management & Finance. He holds the FIRNA Series 65 license. Stacey Alderson, CTP Client Service Director Stacey Alderson joined Chandler Asset Management in 2014 and is a Client Service Director. Stacey oversees the daily responsibilities of the Client Service team including client communication, client reporting, and review/processing of client requested account activity. Stacey collaborates with all departments at Chandler to respond to account -related questions and changes, as well as coordinates the onboarding process of new client accounts. Stacey serves as a liaison between clients and the Chandler team to facilitate the onboarding of new client accounts, proactively schedule client meetings, maintain existing client relationships, create and distribute client reports, and respond to client -generated requests. In addition, Stacey has significant expertise in assisting clients with cash flow analysis and in developing and maintaining cash flow projections within their treasury management operations. Stacey began working in the financial services industry in 1998 through positions in both banking and asset management. She earned her B.A. in business administration with an emphasis in accounting from the University of Montevallo. Stacey has received the AFP designation as a Certified Treasury Professional (CTP). Ryan Tauber Managing Director, Business Development Ryan Tauber joined Chandler Asset Management in 2020 and is Managing Director, Business Development. In his role, he is responsible for leading business development which includes the sales and marketing functions for the firm, as well as leveraging our past successes to expand our client base into other institutional and public agency opportunities. Ryan brings 22 years of experience in the financial services industry. Prior to joining Chandler, Ryan held roles with Morgan Stanley, Bank of America, and Union Bank where in addition to business development, his responsibilities included directing both strategy and risk related functions. Ryan is a graduate of the University of Southern California where he received his degree in Finance from the Marshall School of Business. In addition, he received his M.B.A. from Pepperdine University. Firm Administration, Compliance, Administration and Operations rIIINicole Dragoo, JD, IAACP in a President i 6 � INNicole Dragoo serves as President of Chandler Asset Management. She joined the firm in December 2001 in an operations role and served as COO and Chief Compliance Officer from January 2008 to March 2021. Nicole currently oversees firm operations as well as the legal, compliance and administrative functions. Nicole has held various roles working in and managing operations prior to accepting the responsibilities of COO and CCO. Before joining Chandler, Nicole served as a Trading Associate on the institutional fixed income sales desk at Merrill Lynch. Nicole earned her B.A. from the University of San Diego in business economics and her J.D. from the University of San Diego School of Law. She is a member of the State Bar of California, the San Diego County Bar Association, the Southern California Compliance Group, and the Women in Institutional Investments Network. She has also been an active member of Vistage International participating in various key groups since January of 2010. Additionally, Nicole holds the designation of Investment Adviser Certified Compliance Professional (IACCP) and was awarded the 2017 Governance Professional of the Year (small to mid -cap) by Corporate Secretary. Joseph Kolinsky Chief Compliance Officer Joseph Kolinsky joined Chandler Asset Management in January 2020 and assumed the role of Chief Compliance Officer in April 2021. He provides day-to-day guidance and compliance monitoring of the firm's regulatory environment and the legal framework governing SEC -registered investment advisors. Joseph also assists the firm's President with the oversight functions within the firm and administering all aspects of the compliance program. Joseph has 29 years of investment management experience, with 22 of these years being in internal audit and investment company / investment advisory compliance positions. Prior roles include Chief Compliance Officer and Head of Operations with 13D Management in New York City, and Director of Fund Compliance for Pacific Life. Joseph earned his B.A. in Economics from lona College. ® 5 Kristin Franco Director of Investment Operations illb Kristin Franco joined Chandler in 2022 as the Director of Investment Operations She is responsible P P for implementing investment operation best practices, supervising the operations team, and managing the supporting accounting/investment systems and processes Prior to joining the firm, Kristin served as Vice President and Head of Account Implementation in PIMCO's Municipal SMA Client Service and Operations department Kristin has over 15 years in the financial industry where she served in various Client Service and Operational roles at Gurtin Municipal Bond Management LLC, Wells Fargo Advisors, LLC and Merrill Lynch Kristin is a graduate of Humboldt State University where she earned her B A in Psychology with an emphasis in Organizational Management Kristin also received her M A in Management from the University of Redlands with an emphasis in Training, Coaching, and Development CAI Appendix C ACORD Certificate of Liability Insurance ACORD., Client#: 62001 CHANDAST CERTIFICATE OF LIABILITY INSURANCE DATE (MM/DD/YYYY) 8/02/2022 THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER. IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed. If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer any rights to the certificate holder in lieu of such endorsement(s). PRODUCER Starkweather & Shepley PO Box 549 Providence, RI 02901-0549 401 435-3600 CNTACT Connie Roussel NAOME: PHONE 401 435-3600 F°'t 401-735-7059 (A/C, No, 0. I (A/C, No): AE-MAIP• DDRESS: croussel starshe com INSURER(S) AFFORDING COVERAGE NAIL # INSURER A: Travelers Casualty Insurance 19046 INSURED Chandler Asset Management Inc 6225 Lusk Boulevard San Diego, CA 92121 INSURER B : Travelers Insurance Company 25674 Hartford Fire Insurance Company INSURER c : P y 19682 issuers D : Twin City Fire Insurance Company 29459 INSURER E : Houston Casualty Co 42374 INSURER F : Scottsdale Insurance 41297 COVERAGES CERTIFICATE NUMBER: REVISION NUMBER: THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS. INSR LTR TYPE OF INSURANCE ADDL LT INSR L POLICY NUMBER POLICY EFF (MM/DD/YYYY) POLICY EXP (MM/DDM/YY) LIMITS A X COMMERCIAL GENERAL LIABILITY CLAIMS -MADE El OCCUR 6802C07960542 09/01/2022 09/01/2023 - cucc OCCURRENCE $2,000,000 PREMISES (EaEcgunDence) $1,000,000 MED EXP (Any one person) $ 5,000 PERSONAL 8 ADV INJURY $2,000,000 GENERAL AGGREGATE $4,000,000 GEN'L AGGREGATE LIMIT APPLIES PER: POLICY ElJPRO ECT LOC OTHER: PRODUCTS - COMP/OP AGG $4,000,000 A AUTOMOBILE LIABILITY X ANY AUTO OWNED _ AUTOS ONLY HIRED X AUTOS ONLY X Drive Oth Car SCHEDULED AUTOS NON-OWN=D X AUTOS ONLY BA4N11595742 09/01/2022 09/01/2023 alldeDtSINGLE LIMIT $1,000,000 BODILY INJURY (Per person) $ BODILY INJURY (Per accident) $ PROPERTY DAMAGE (Per accident) $ $ B X UMBRELLA LIAB EXCESS LIAR X OCCUR CLAIMS -MADE CUP2C08502242 09/01/2022 09/01/2023 EACH OCCURRENCE $10,000,000 AGGREGATE $10,000,000 $ DED I XI RETENTION $0 C YERS'LIAILIT AND EMPLOYERS' LIABILITY AND ANY PROPRIETORIPARTNETION R/EXECUTIVE YIN OFFICER/MEMBER EXCLUDED? (Mandatory In NH) If yes, describe under DESCRIPTION OF OPERATIONS below N / A 02WECCR2756 09/01/2022 09/01/2023 X ISTATUTE I IERH E.L. EACH ACCIDENT $1,000,000 E.L. DISEASE - EA EMPLOYEE $1,000,000 E.L. DISEASE - POLICY LIMIT $1,000,000 D E C Professional Cyber Liab Crime 08DC521984522 H21NGP20973101 08FA024546722 08/02/2022 08/02/2022 08/02/2022 08/02/2023 08/02/2023 08/02/2023 $10,000,000 $4,000,000 $10,000,000 DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required) F. Employment Practices Liability EKS3440466 Eff Date: 8-02-2022 Exp Date: 8-02-2023 Limit $1,000,000 Endurance Risk Solutions #43630 - 1st Excess Professional Liab FIX30001867802 Eff Date: 8-02-2022 Exp Date: 8-02-2023 Limit $10,000,000 (See Attached Descriptions) CERTIFICATE HOLDER CANCELLATION Authority for California Cities Excess Liability C/o Alliant Ins. Services Inc. 560 Mission Street 6th Floor San Francisco, CA 94105 SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS. AUTHORIZED' REPRESENTATIVE ©1988-2015 ACORD CORPORATION. All rights reserved. ACORD 25 (2016/03) 1 of 2 The ACORD name and logo are registered marks of ACORD #S1957400/M1957087 BHE DESCRIPTIONS (Continued from Page 1) Everest National #10120 - 2nd Excess Prof Liability FL5EX00728221 Eff Date: 8-02-2022 Exp Date: 8-02 2023 Limit $10,000,000 SAGITTA 25.3 (2016/03) 2 of 2 #S1957400/M1957087 GM Appendix D Global Investment Performance Standards (GIPS®) and Verification Letter ACAI' CAS Verification Report Chandler Asset Management, Inc. We have verified whether Chandler Asset Management, Inc. (the "Firm'') has, for the periods from July 1, 1997 through March 31, 2021, established policies and procedures for complying with the Global Investment Performance Standards (GIPS®) related to composite and pooled fund maintenance and the calculation, presentation, and distribution of performance that are designed in compliance with the GIPS standards, as well as whether these policies and procedures have been implemented on a firm -wide basis. 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 Finn's management is responsible for its claim of compliance with the GIPS standards and the design and implementation of its policies and procedures. Our responsibilities are to be independent from the Firm and to express an opinion based on our verification. We conducted this verification in accordance with the required verification procedures of the GIPS standards, which includes testing performance on a sample basis. We also conducted such other procedures as we considered necessary in the circumstances. In our opinion, for the periods from July 1, 1997 through March 31, 2021, the Finn's policies and procedures for complying with the GIPS standards related to composite and pooled fund maintenance, as well as the calculation, presentation, and distribution of performance, have been, in all material respects: • Designed in compliance with the GIPS standards, and • Implemented on a firm -wide basis. This report does not relate to or provide assurance on any specific performance report of the Firm or on the operating effectiveness of the Firm's controls or policies and procedures for complying with the GIPS standards. 747e71,1.49ree, ACA Group, Performance Services Division January 25, 2022 Annual Rates of Return 2011 throw _ h 2021 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 0.81% 0.74% 0.39% 0.46% 0.46% 0.97% 0.99% 1.97% 3.29% 2.08% -0.16% 0.56% 0.49% 0.14% 0.20% 0.21% 0.71% 0.74% 1.72% 3.04% 1.83% -0.41% 0.73% 0.26% 0.22% 0.29% 0.30% 0.65% 0.71% 1.77% 2.88% 1.76% -0.17% 0.45% 0.42% 55 05 119 2.01% 5,929 0.37% 0.31% 05 ≤5 77 1.20% 6,431 0.25% 0.21% ≤5 ≤5 58 0.81% 7,165 0.22% 0.17% ≤5 ≤5 74 0.83% 8,894 0.23% 0.23% .05 55 62 0.53% 11,747 0.30% 0.32% 05 55 80 0.62% 12,882 0.29% 0.32% 0.09% ≤5 86 0.63% 13,698 0.34% 0.40% 0.05% ≤5 59 0.35% 16,551 0.44% 0.47% ≤5 55 66 0.34% 19,552 0.52% 0.63% 0.04% 55 66 0.29% 22,227 0.62% 0.67% 0.00% ≤5 64 0.25% 25,785 Gil I Chandler Asset Management claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. Chandler Asset Management has been independently verified by ACA Performance Services for the period of July 1, 1997 through March 31, 2021. 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 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. 1. Chandler Asset Management is an independent investment adviser registered as such with the Securities and Exchange Commission under the Investment Adviser's Act of 1940. Registration with the SEC does not imply a certain level of skill or training. Since 1988, Chandler Asset Management has provided fixed income investment management services to the public sector, as well as to foundations, endowments, individuals and corporations. A complete list and description of all of the firm's composites is available upon request. 2. The Ultra Short Bond Composite is a composite of individually managed accounts with an average modified duration approximately equal to the modified duration of the ICE BofA Blended 0-3 year Treasury index and a maximum final stated maturity of individual securities of three years. The minimum account size required to be included in this composite is $2 million. This composite was created in November 1988. The name of this composite was changed from Principal Preservation effective June 30, 2009. 3. The ICE BofA Blended 0-3 Year US Treasury Index is a static, internally maintained benchmark comprised of US dollar denominated sovereign debt publicly issued by the US government in its domestic market. Effective 1/1/2001, it consists of the following indices: (30%) ICE BofA US 3 -Month Treasury Bill Index, (30%) ICE BofA US 6 -Month Treasury Bill Index, (40%) ICE BofA 1-3 Year US Treasury Index. Qualifying securities will include 3 and 6 -month Treasury Bills and US Treasury securities that must have at least one year remaining term to final maturity and less than three years remaining term to final maturity, a fixed coupon schedule, and a minimum amount outstanding of $1 billion. Qualifying securities must have at least 18 months to final maturity at the time of issuance.*Prior to 1/1/2001 it consisted of (100%) ICE BofA US 1 -Year Treasury Bill Index, 0003. Indexes are referred to for comparative purposes only and are not intended to parallel the risk or investment style of the portfolios in the Composite. Indexes do not utilize leverage. Index calculations do not reflect fees, brokerage commissions or other expenses of investing. Investors may not make direct investments into any index. Index data contained herein (and all trademarks related thereto) are owned by the indicated index provider, and may not be redistributed. The information herein has not been approved by the index provider. 4. Valuations are computed and performance reported in U.S. Dollars. 5. Performance is calculated using a time -weighted total rate of return, which links performance monthly, and is reported gross of investment management fees and custodial fees, but after all trading expenses. Results reflect the reinvestment of income, dividends and other earnings, and include realized and unrealized gains and losses and interest accrued through the last day of each month. Results do not reflect the potential impact of taxes. Past performance is not indicative of future results. Fees charged by Chandler Asset Management will reduce performance. 6. Net -of -fees performance returns are calculated by reducing the monthly gross performance by one -twelfth (1/12) of the actual maximum applicable fee of 0.25%, which is representative of our current fee schedule for this composite. These monthly returns are then geometrically linked to produce annual returns which are presented before custodial fees but after management fees and all trading expenses. Fees are negotiable and additional information regarding Chandler's fees is included in our Part 2A of Form ADV. 7. Dispersion is calculated using the asset weighted standard deviation of annual gross returns of those portfolios that were included in the composite for the entire year. For years when less than six portfolios were included in the composite for the full year, no dispersion measure is presented. The three-year annualized standard deviation measures the variability of the composite gross returns and the benchmark returns over the preceding 36 -month period. Policies for valuing investments, calculating performance, and preparing GIPS reports are available upon request. 8. 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. Source ice Data Indices, LLC ("ICE"), used with permission. ICE permits the use of ICE Indices and related data on an "as is" basis; ICE, its affiliates and their respective third party suppliers disclaim any and all warranties and representation, express and/or implied, including any warranties of merchantability or fitness fora particular purpose or use, including the indices, index data and any data included in, related to, or derived therefrom. Neither ICE data, its affiliates or their respective third -party providers guarantee the quality, adequacy, accuracy, timeliness or completeness of the indices or the index data or any component thereof, and the indices and index data and all components thereof are provided on an "as is" basis and licensee's use is at licensee's own risk. ICE data, its affiliates and their respective third party do not sponsor, endorse, or recommend Chandler, or any of its products or services. 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 1.88% 1.16% 0.30% 0.87% 0.74% 1.11% 0.85% 1.69% 3.87% 3.25% -0.48% 1.62% 0.91% 0.05% 0.61% 0.49% 0.86% 0.60% 1.44% 3.61% 3.00% -0.73% 1.55% 0.43% 0.36% 0.62% 0.54% 0.88% 0.43% 1.59% 3.55% 3.12% -0.55% Annual Rates of Return 2011 through 2021 1.02% 1.02% 0.31% 9 222 3.74% 5,929 0.78% 0.73% 0.06% 15 474 7.37% 6,431 0.59% 0.50% 0.08% 18 797 11.12% 7,165 0.54% 0.43% 0.09% 21 879 9.88% 8,894 0.63% 0.56% 0.07% 27 1,328 11.31% 11,747 0.74% 0.76% 0.06% 31 1,081 8.39% 12,882 0.71% 0.74% 0.08% 32 1,178 8.60% 13,698 0.77% 0.85% 0.03% 31 1,905 11.51% 16,551 0.84% 0.94% 0.08% 39 2,653 13.57% 19,552 0.92% 1.21% 0.12% 39 2,713 12.21% 22,227 0.96% 1.19% 0.07% 44 3,189 12.37% 25,785 Chandler Asset Management claims compliance with the Global Investment Performance Standards (GIPS') and has prepared and presented this report in compliance with the GIPS standards. Chandler Asset Management has been independently verified by ACA Performance Services for the period of July 1, 1997 through March 31, 2021. 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 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. 1. Chandler Asset Management is an independent investment adviser registered as such with the Securities and Exchange Commission under the Investment Adviser's Act of 1940. Registration with the SEC does not imply a certain level of skill or training. Since 1988, Chandler Asset Management has provided fixed income investment management services to the public sector, as well as to foundations, endowments, individuals and corporations. A complete list and description of all of the firm's composites is available upon request. 2. The Limited Maturity Composite is a composite of individually managed accounts with an average modified duration approximately equal to the modified duration of the ICE BofA 1-3 Year US Treasury Index and a final stated maturity of individual securities of five years. The minimum account size required to be included in this composite is $2 million. This composite was created September 1988. The name of this composite was changed from Short -Term Fixed Income effective June 30, 2009. 3. The ICE BofA 1-3 Year US Treasury Index tracks the performance of US dollar -denominated sovereign debt publicly issued by the US government in its domestic market. Qualifying securities must have at least one year remaining term to final maturity and less than three years remaining term to final maturity, a fixed coupon schedule, and a minimum amount outstanding of $1 billion. Qualifying securities must have at least 18 months to final maturity at the time of issuance. Indexes are referred to for comparative purposes only and are not intended to parallel the risk or investment style of the portfolios in the Composite. Indexes do not utilize leverage. Index calculations do not reflect fees, brokerage commissions or other expenses of investing. Investors may not make direct investments into any index. Index data contained herein (and all trademarks related thereto) are owned by the indicated index provider, and may not be redistributed. The information herein has not been approved by the index provider. 4. Valuations are computed and performance reported in U.S. Dollars. 5. Performance is calculated using a time -weighted total rate of return, which links performance monthly, and is reported gross of investment management fees and custodial fees, but after all trading expenses. Results reflect the reinvestment of income, dividends and other earnings, and include realized and unrealized gains and losses and interest accrued through the last day of each month. Results do not reflect the potential impact of taxes. Past performance is not indicative of future results. Fees charged by Chandler Asset Management will reduce performance. 6. Net -of -fees performance returns are calculated by reducing the monthly gross performance by one -twelfth (1/12) of the actual maximum applicable fee of 0.25%, which is representative of our current fee schedule for this composite. These monthly returns are then geometrically linked to produce annual returns which are presented before custodial fees but after management fees and all trading expenses. Fees are negotiable and additional information regarding Chandler's fees is included in our Part 2A of Form ADV. 7. Dispersion is calculated using the asset weighted standard deviation of annual gross returns of those portfolios that were included in the composite for the entire year. For years when less than six portfolios were included in the composite for the full year, no dispersion measure is presented. The three-year annualized standard deviation measures the variability of the composite gross returns and the benchmark returns over the preceding 36 - month period. Policies for valuing investments, calculating performance, and preparing GIPS reports are available upon request. 8. 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. Source ice Data Indices, LLC ("ICE"), used with permission. ICE permits the use of ICE Indices and related data on an "as is" basis; ICE, its affiliates and their respective third party suppliers disclaim any and all warranties and representation, express and/or implied, including any warranties of merchantability or fitness fora particular purpose or use, including the indices, index data and any data included in, related to, or derived therefrom. Neither ICE data, its affiliates or their respective third -party providers guarantee the quality, adequacy, accuracy, timeliness or completeness of the indices or the index data or any component thereof, and the indices and index data and all components thereof are provided on an "as is" basis and licensee's use is at licensee's own risk. ICE data, its affiliates and their respective third party do not sponsor, endorse, or recommend Chandler, or any of its products or services. Annual Rates of Return 2011 through 2021 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2.90% 1.80% 0.04% 1.42% 1.15% 1.30% 1.08% 1.53% 4.55% 4.43% -0.93% 2.64% 1.54% -0.21% 1.17% 0.90% 1.04% 0.83% 1.27% 4.29% 4.17% -1.17% 3.19% 0.98% -0.16% 1.24% 0.96% 1.08% 0.67% 1.55% 4.19% 4.22% -1.09% 1.47% 1.65% 0.07% 32 1,866 31.48% 5,929 1.18% 1.27% 0.26% 38 2,133 33.17% 6,431 1.02% 1.10% 0.08% 39 2,168 30.26% 7,165 0.96% 0.99% 0.07% 40 2,325 26.14% 8,894 1.11% 1.18% 0.07% 44 3,403 28.97% 11,747 1.24% 1.39% 0.05% 49 4,131 32.07% 12,882 1.19% 1.34% 0.11% 48 3,783 27.62% 13,698 1.22% 1.40% 0.05% 48 3,485 21.06% 16,551 1.22% 1.39% 0.19% 55 5,199 26.59% 19,552 1.32% 1.70% 0.11% 59 6,234 28.05% 22,227 1.33% 1.65% 0.04% 72 7,294 28.29% 25,785 CM Chandler Asset Management claims compliance with the Global Investment Performance Standards (GIPS.) and has prepared and presented this report in compliance with the GIPS standards. Chandler Asset Management has been independently verified by ACA Performance Services for the period of July 1, 1997 through March 31, 2021. 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 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. 1. Chandler Asset Management is an independent investment adviser registered as such with the Securities and Exchange Commission under the Investment Adviser's Act of 1940. Registration with the SEC does not imply a certain level of skill or training. Since 1988, Chandler Asset Management has provided fixed income investment management services to the public sector, as well as to foundations, endowments, individuals and corporations. A complete list and description of all of the firm's composites is available upon request. 2. The Short Term Bond Composite is a composite of individually managed accounts with an average modified duration approximately equal to the modified duration of the ICE BofA 1-5 Year US Treasury & Agency Index and a maximum final stated maturity of individual securities of five years. The minimum account size required to be included in this composite is $2 million. This composite was created in September 1995. The name of this composite was changed from 1-5 Year Government Fixed Income effective June 30, 2009. 3. The ICE BofA 1-5 Year US Treasury & Agency Index tracks the performance of US dollar denominated US Treasury and nonsubordinated US agency debt issued in the US domestic market. Qualifying securities must have an investment grade rating (based on an average of Moody's, S&P and Fitch). Qualifying securities must have at least one year remaining term to final maturity and less than five years remaining term to final maturity, at least 18 months to maturity at time of issuance, a fixed coupon schedule, and a minimum amount outstanding of $1 billion for sovereigns and $250 million for agencies. Indexes are referred to for comparative purposes only and are not intended to parallel the risk or investment style of the portfolios in the Composite. Indexes do not utilize leverage. Index calculations do not reflect fees, brokerage commissions or other expenses of investing. Investors may not make direct investments into any index. Index data contained herein (and all trademarks related thereto) are owned by the indicated index provider, and may not be redistributed. The information herein has not been approved by the index provider. 4. Valuations are computed and performance reported in U.S. Dollars. 5. Performance is calculated using a time -weighted total rate of return, which links performance monthly, and is reported gross of investment management fees and custodial fees, but after all trading expenses. Results reflect the reinvestment of income, dividends and other earnings, and include realized and unrealized gains and losses and interest accrued through the last day of each month. Results do not reflect the potential impact of taxes. Past performance is not indicative of future results. Fees charged by Chandler Asset Management will reduce performance. 6. Net -of -fees performance returns are calculated by reducing the monthly gross performance by one -twelfth (1/12) of the actual maximum applicable fee of 0.25%, which is reflective of our current fee schedule for this composite. These monthly returns are then geometrically linked to produce annual returns which are presented before custodial fees but after management fees and all trading expenses. Fees are negotiable and additional information regarding Chandler's fees is included in our Part 2A of Form ADV. 7. Dispersion is calculated using the asset weighted standard deviation of annual gross returns of those portfolios that were included in the composite for the entire year. For years when less than six portfolios were included in the composite for the full year, no dispersion measure is presented. The three-year annualized standard deviation measures the variability of the composite gross returns and the benchmark returns over the preceding 36 - month period. Policies for valuing investments, calculating performance, and preparing GIPS reports are available upon request. 8. 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. Source ice Data Indices, LLC ("ICE"), used with permission. ICE permits the use of ICE Indices and related data on an "as is" basis; ICE, its affiliates and their respective third party suppliers disclaim any and all warranties and representation, express and/or implied, including any warranties of merchantability or fitness for a particular purpose or use, including the indices, index data and any data included in, related to, or derived therefrom. Neither ICE data, its affiliates or their respective third -party providers guarantee the quality, adequacy, accuracy, timeliness or completeness of the indices or the index data or any component thereof, and the indices and index data and all components thereof are provided on an "as is" basis and licensee's use is at licensee's own risk. ICE data, its affiliates and their respective third party do not sponsor, endorse, or recommend Chandler, or any of its products or services. CM Appendix E Important Disclosures CAS IMPORTANT DISCLOSURES ICE BofA Blended 0-3 Year US Treasury Index The ICE BofA Blended 0-3 Year US Treasury Index is a static, internally maintained benchmark comprised of US dollar denominated sovereign debt publicly issued by the US government in its domestic market. Effective 1/1/2001, it consists of the following indices: (30%) ICE BofA US 3 -Month Treasury Bill Index, (30%) ICE BofA US 6 - Month Treasury Bill Index, (40%) ICE BofA 1-3 Year US Treasury Index. Qualifying securities will include 3 and 6 - month Treasury Bills and US Treasury securities that must have at least one year remaining term to final maturity and less than three years remaining term to final maturity, a fixed coupon schedule, and a minimum amount outstanding of $1 billion. Qualifying securities must have at least 18 months to final maturity at the time of issuance.*Prior to 1/1/2001 it consisted of (100%) ICE BofA US 1 -Year Treasury Bill Index, G0O3. ICE BofA 1-3 Year US Treasury Index The ICE BofA 1-3 Year US Treasury Index tracks the performance of US dollar -denominated sovereign debt publicly issued by the US government in its domestic market. Qualifying securities must have at least one year remaining term to final maturity and less than three years remaining term to final maturity, a fixed coupon schedule, and a minimum amount outstanding of $1 billion. Qualifying securities must have at least 18 months to ICE BofA 1-S Year US Treasury & Agency Index The ICE BofA 1-5 Year US Treasury & Agency Index tracks the performance of US dollar denominated US Treasury and nonsubordinated US agency debt issued in the US domestic market. Qualifying securities must have an investment grade rating (based on an average of Moody's, S&P and Fitch). Qualifying securities must have at least one year remaining term to final maturity and less than five years remaining term to final maturity, at least 18 months to maturity at time of issuance, a fixed coupon schedule, and a minimum amount outstanding of $1 billion for sovereigns and $250 million for agencies. Source ICE Data Indices, LLC ("ICE"), used with permission. ICE permits use of ICE indices and related data on an "as is" basis; ICE, its affiliates and their respective third -party suppliers disclaim any and all warranties and representations, express and/or implied, including any warranties of merchantability or fitness for a particular purpose or use, including the indices, index data and any data included in, related to, or derived therefrom. Neither ICE Data, its affiliates or their respective third -party providers guarantee the quality, adequacy, accuracy, timeliness or completeness of the indices or the index data or any component thereof, and the indices and index data and all components thereof are provided on an "as is" basis and licensee's use is at licensee's own risk. ICE Data, its affiliates and their respective third party do not sponsor, endorse, or recommend Chandler Asset Management, or any of its products or services. This report is being provided for informational purposes only. No investment decision should be made based solely on the information provided herein. All investments involve risk, including loss of principal invested. The strategies referenced may not be suitable for all investors. The information contained herein is based on internal research derived from various sources and does not purport to be statements of all material facts relating to the strategies. While not guaranteed as to accuracy or completeness, some of the information has been obtained from sources we believe to be reliable. Third -party source information is provided by independent sources deemed to be reliable but is not guaranteed. Opinions expressed herein are subject to change without notice. There can be no assurance that an account or specific investment product will be able to achieve its investment objective. No guarantee of investment performance is being provided and no inference to the contrary should be made. Index returns assume reinvestment of all distributions. Historical performance results for investment indexes generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment management fee, the incurrence of which would have the effect of decreasing historical performance results. It is not possible to invest directly in an index. Index Descriptions and Disclosures 1 I P a g e CM Fixed income investments are subject to interest, credit, and market risk. Interest rate risk: the value of fixed income investments will decline as interest rates rise. Credit risk: the possibility that the borrower may not be able to repay interest and principal. Low rated bonds generally have to pay higher interest rates to attract investors willing to take on greater risk. Market risk: the bond market in general could decline due to economic conditions, especially during periods of rising interest rates. Index Descriptions and Disclosures 2 I P a g e Appendix F a7N.�tic'l,-4_!'x"+iY�'sX_'3M.E1�:F1g;5'Ftit.Jiti2S'S'.'.73'. ry5.Y:. X�?'S.'Si4�A4kk1n ntilTYs.�::'7N;42MfSti1>2Xi15r 9fi.W.i�iR�k L�:':t.f3M>'vHfSh7`Y:..:aW,+YM�V"4'_ 'SfY�elft�eM "i��lie..'faa:.-_'. .t5'.�t7"a', Sample Client Monthly Statement, Quarterly Report and GASB 40 and 72 Reports Sample Client - Account #000000 MONTHLY ACCOUNT STATEMENT JULY 1, 2018 THROUGH JULY 31, 2018 Chandler Team: For questions about your account, please call (800) 317-4747, or contact operations@chandlerasset.com Custodian: Bank Name Contact Telephone Number CHANDLER ASSET MANAGEMENT chandlerasset.com Information contained herein is confidential. We urge you to compare this statement to the one you receive from your qualified custodian. Please see Important Disclosures. Please note: This sample client service report is being provided for illustrative purposes to demonstrate Chandler Asset Management's reporting capabilities. References to specific securities and their characteristics are examples of securities held in the portfolio and are not intended to be, and should not be interpreted as an offer, solicitation or recommendation to purchase or sell any financial instrument, an indication that the purchase of such securities was or will be profitable, or representative of the composition or performance of the portfolio. The information contained in this sample presentation was obtained from sources we believe to be reliable, but we do not guarantee its accuracy. This presentation contains the current opinions of the author, which are subject to change without notice. Any statements concerning financial market trends or future forecasts are based on current market conditions, which will fluctuate. Past performance is not indicative of future success. Sample Client Account #000000 Portfolio Summary As of Month -end Date CA PORTFOLIO CHARACTERISTICS Average Modified Duration Average Coupon Average Purchase YTM Average Market YTM Average S&P/Moody Rating Average Final Maturity Average Life 1.65 1.71% 1.76% 2.63% AA+/Aa 1 1.71 yrs 1.71 yrs SECTOR ALLOCATION Agency US Treasury Corp Comm Paper 32.3% i 2.0% 15.1% Foreign Corp 1.3% Money MM Id 0.7% PERFORMANCE REVIEW ACCOUNT SUMMARY Beg. Values as of 6/30/18 End Values as of 7/31/18 Market Value Accrued Interest Total Market Value Income Earned Cont/WD Par Book Value Cost Value 76,345,943 326,558 76,401, 796 325,766 76,672,501 108,722 77,522,170 77,312,026 77,390,949 76,727,562 114,931 0 77,662,679 77,427,515 77,513,133 MATURITY DISTRIBUTION 15% 20% 15 10% 5.7% 19.5% 3.9% ■ 31.7% 27.6% 10.3% 1.3% t? -.25 .25-.5 .5-1 1-2 2-3 3-4 4.5 5+ Maturity (Yrs) TOP ISSUERS U nited States Government U .S. Agency U .S. Agency U .S. Agency U .S. Agency Corporate Security Asset -Backed Security Corporate Security Total 32.3% 16.8% 15.0% 12.3% 4.5% 2.0% 1.7% 1.4% 86.0% CREDIT QUALITY (S&P) AA (90.1%) AAA {1.9%) A (8.1%) TOTAL RATE OF RETURN Sample Client Sample Index 1M 0.00% 0.00% 3M 0.00% 0.00% YTD 0.00% 0.00% Annualized 1YR 2YRS 0.00% 0.00% 0.00% 0.00% 3YRS 0.00% 0.00% 5Y RS N/A N/A 10YRS N/A N/A 2/28/2015 0.00% 0.00% This report is intended as a representative illustration of our monthly reporting capabilities only and is not intended as a representation of our performance. Performance is presented gross of investment management fees. Investment advisory fees are described in the firm's Form ADV Part 2A Brochure and will reduce returns. References to specific securities and their characteristics are examples of securities held in the portfolio and are not intended to be, and should not be interpreted as an offer, solicitation or recommendation to purchase or sell any financial instrument, an indication that the purchase of such securities was or will be profitable, or representative of the composition or performance of the portfolio. Past performance is not indicative of future results. Chandler Asset Management - CONFIDENTIAL Page 1 Execution Time: 8/21/2018 9:23:32 PM Statement of Compliance As of Month -end Date Sample Client Category Treasury/Agency Issues Time Deposits/Certificates of Deposit Negotiable CDs Commercial Paper Medium Term Notes Money Market Mutual Funds Mortgage Pass Throughs Asset -Backed Securities LAIF Prohibited Max Per Issuer Assets managed by Chandler Asset Management are in full compliance with state law and the Client's investment instructions. Standard No Limit FDIC insured or fully collateralized "AA" or higher by two NRSROs; 30% maximum; 2% per issuer "A-1" or higher short term rating by two NRSROs; and "A" or higher by two NRSROs, if long-term debt; 25% maximum; 2% per issuer; 270 days max maturity "A" rated or better by two NRSROs; 25% maximum; 12.5% maximum if rated "A" by two NRSROs; 2% per issuer if rated AA or higher; 1.5% per issuer if rated A; Issued by corporations organized and operating within the U.S. or by depository institutions licensed by the U.S. or any state and operating within the U.S. "AAA" rated by 2 NRSROs or SEC registered with AUM >$500 million; 20% maximum; 10% per fund Federal Agency guaranteed; 20% maximum "AAA" rated or better by two NRSROs; "A" rated or higher for the issuer's debt by two NRSROs; 10% maximum; 2% per issuer; Prior consent with Director of Finance required Prohibited for outside manager Inverse floaters; Ranges notes, Interest -only strips from mortgaged backed securities; Zero interest accrual securities; Reverse Repurchase Agreements; Futures/ Options prohibited without specific approval of the Finance Director 2% of portfolio per issuer (except U.S. government, Agencies, and Money Market Funds) Maximum Maturity 5 years Comment Complies Complies Complies Complies CA Complies - 16.9% total; 8.9% "A" rated by two NRSROs Complies Complies Complies Complies Complies Complies Complies Page 2 Sample Client Account #000000 Reconciliation Summary As of Month -end Date BEGINNING BOOK VALUE Acquisition + Security Purchases + Money Market Fund Purchases + Money Market Contributions + Security Contributions + Security Transfers Total Acquisitions Dispositions - Security Sales - Money Market Fund Sales - MMF Withdrawals - Security Withdrawals - Security Transfers - Other Dispositions - Maturites - Calls - Principal Paydowns Total Dispositions Amortization/Accretion +/- Net Accretion $1,972,010.00 $452,020.63 $0.00 $0.00 $0.00 Gain/Loss on Dispositions +/- Realized Gain/Loss ENDING BOOK VALUE $999,609.38 $1,001,512.22 $0.00 $0.00 $0.00 $0.00 $310,000.00 $0.00 $0.00 $2,814.81 $77,312,026.12 $2,424,030.63 ($234.79) $2,311,121.60 $2,814.81 ($234.79) $77,427,515.17 CASH TRANSACTION SUMMARY BEGINNING BALANCE Acquisition Contributions Security Sale Proceeds Accrued Interest Received Interest Received Dividend Received Principal on Maturities Interest on Maturities Calls/Redemption (Principal) Interest from Calls/Redemption Principal Paydown Total Acquisitions Dispositions Withdrawals Security Purchase Accrued Interest Paid Total Dispositions ENDING BOOK VALUE $1,097,170.35 $0.00 $999,609.38 $6,236.41 $106,675.00 $2,664.28 $310,000.00 $0.00 $0.00 $0.00 $0.00 $1,425,185.07 $0.00 $1,972,010.00 $2,666.66 $1,974,676.66 $547,678.76 Chandler Asset Management - CONFIDENTIAL Page 3 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Holdings Report As of Month -end Date Calk CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration AGENCY Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.125% Due 12/14/2018 Sample Issuer 2% Due 9/14/2018 Sample Issuer 1.625% Due 11/27/2018 Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.5% Due 3/8/2019 Sample Issuer 1.125% Due 4/15/2019 1.75% Due 5/30/2019 Sample Issuer 1.125% Due 6/21/2019 Sample Issuer 1.25% Due 8/1/2019 Sample Issuer 1.75% Due 9/12/2019 Sample Issuer 1.375% Due 9/13/2019 Sample Issuer 1.25% Due 10/2/2019 Sample Issuer 1.5% Due 1/17/2020 Sample Issuer 1.5% Due 2/28/2020 Sample Issuer 1.875% Due 3/13/2020 1,500,000.00 2,000,000.00 1,000,000.00 1,500,000.00 2,000,000.00 1,350,000.00 1,500,000.00 1,500,000.00 1,525,000.00 1,500,000.00 2,000,000.00 1,520,000.00 2,000,000.00 750,000.00 02/07/2014 1.50% Various 1.57% 1,533,345.00 1,500,874.89 2,005,390.00 2,000,348.26 99.99 2.06% 99.83 2.14% 12/15/2015 1.38% 02/12/2016 1.03% Various 1.01% 08/18/2014 1.64% 06/28/2016 0.83% 06/28/2016 0.86% Various 1.86% 08/24/2016 1.02% Various 1.04% 01/12/2017 1.54% 992,620.00 999,089.31 1,521,015.00 1,504,123.91 2,007,055.00 2,001,654.04 1,356,966.00 1,351,205.58 1,513,035.00 1,503,885.32 1,517,565.00 1,505,683.71 1,517,171.50 1,523,246.80 1,515,960.00 1,505,845.31 2,012,700.00 2,004,918.61 1,518,358.40 1,519,199.44 99.62 2.15% 99.54 2.27% 99.14 2.36% 99.46 2.40% 98.86 2.43% 98.81 2.46% 99.15 2.53% 98.75 2.52% 1,499,865.00 11,416.68 1,996,686.00 5,777.77 996,233.00 1,468.75 1,493,130.00 8,937.50 1,982,808.00 6,625.00 1,342,755.90 4,003.13 1,482,847.50 1,875.00 1,482,193.50 9,375.00 1,512,069.53 10,304.34 98.52 2.54% 1,481,248.50 7,906.25 1,970,390.00 8,263.88 98.45 2.58% 1,496,509.92 886.67 Various 1.56% Sample Issuer 1.55% Due 5/8/2020 2,000,000.00 Sample Issuer 1.75% Due 6/12/2020 1,500,000.00 05/03/2017 1.57% 05/23/2017 1.58% 06/15/2017 1.59% 1,996,672.00 1,998,209.40 756,382.50 753,606.97 1,998,340.00 1,999,007.07 1,506,855.00 1,504,274.96 98.22 2.66% 1,964,314.00 12,750.00 1.97% (1,009.89) 2.61% (3,662.26) 1.30% (2,856.31) 1.96% (10,993.91) 2.59% (18,846.04) 1.76% (8,449.68) 1.94% (21,037.82) 1.94% (23,490.21) 1.98% (11,177.27) 1.94% (24,596.81) 2.58% (34,528.61) 1.95% (22,689.52) 2.58% (33,895.40) Aaa / AA+ AAA 0.12 0.12 Aaa / AA+ AAA 0.33 0.32 Aaa / AA+ AAA 0.37 0.37 Aaa / AA+ AAA 0.60 0.59 Aaa / AA+ AAA 0.71 0.69 Aaa / AA+ AAA 0.83 0.82 Aaa / AA+ AAA 0.89 0.88 Aaa / AA+ AAA 1.00 0.98 Aaa / AA+ AAA 1.12 1.09 Aaa / AA+ N R 1.12 1.09 Aaa / AA+ AAA Aaa / AA+ AAA 1.17 1.15 1.47 1.43 Aaa / AA+ AAA 1.58 1.53 98.72 2.69% 98.08 2.67% 98.26 2.71% 740,382.00 5,390.63 1,961,588.00 7,147.22 1,473,907.50 3,572.92 0.97% (13,224.97) 2.57% (37,419.07) 1.93% (30,367.46) Aaa / AA+ N R Aaa / AA+ AAA 1.62 1.57 1.77 1.72 Aaa / AA+ N R 1.87 1.81 Chandler Asset Management - CONFIDENTIAL Page 4 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Holdings Report tt As of Month -end Date ____ CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration AGENCY Sample CUSIP Sample Issuer 1.375% Due 9/28/2020 Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.68% Due 10/13/2020 Sample Issuer 1.875% Due 11/17/2020 1,500,000.00 1,500,000.00 1,250,000.00 Sample Issuer 2.375% Due 2/16/2021 Sample Issuer 2.375% Due 3/12/2021 Sample Issuer 2.5% Due 4/13/2021 1,000,000.00 2,000,000.00 1,000,000.00 09/14/2017 1.59% 10/18/2017 1.78% 11/27/2017 1.95% 04/20/2018 2.66% 03/26/2018 2.54% 1,490,535.00 1,493,266.11 1,495,845.00 1,496,935.21 1,247,450.00 1,248,028.16 97.16 2.74% 97.69 2.77% 1,457,452.50 7,046.88 1,465,302.00 7,560.00 1.91% (35,813.61) 1.92% (31,633.21) Aaa / AA+ NR 2.16 2.10 98.05 2.76% 992,270.00 993,020.49 1,990,840.00 1,991,916.15 98.96 2.80% 98.45 2.99% 1,225,591.25 4,817.71 989,615.00 10,885.42 1,969,042.00 18,340.28 1.60% (22,436.91) Aaa / AA+ AAA Aaa / AA+ AAA 2.21 2.13 2.30 2.22 1.30% (3,405.49) 2.59% (22,874.15) Aaa / AA+ AAA 2.55 2.42 Aaa / AA+ AAA 2.62 2.49 Sample Issuer 1.875% Due 6/11/2021 Sample Issuer 2.75% Due 6/22/2021 Sample Issuer 1.125% Due 8/12/2021 1,250,000.00 1,000,000.00 1,000,000.00 06/15/2018 2.72% 08/30/2017 1.67% 07/10/2018 2.74% 993,920.00 994,179.73 1,259,425.00 1,257,137.05 1,000,290.00 1,000,284.35 10/04/2016 1.37% Sample CUSIP Sample Issuer 2% Due 1/5/2022 1,000,000.00 07/30/2018 2.87% 988,440.00 992,778.26 971,720.00 971,742.55 Total Agency 37, 645,000.00 1.61% 37,700,165.40 37,614,461.64 99.14 2.83% 97.32 2.86% 99.77 2.83% 95.11 2.82% 97.09 2.90% 2.58% 991,369.00 7,500.00 1,216,468.75 3,255.21 997,684.00 2,750.00 951,132.00 5,281.25 970,860.00 1,444.44 37,111,444.85 174,581.93 1.30% (2,810.73) 1.59% (40,668.30) 1.30% (2,600.35) Aaa / AA+ AAA 2.70 2.57 Aaa / AA+ AAA 2.87 2.75 Aaa / AA+ AM 2.90 2.75 1.25% (41,646.26) 1.27% (882.55) 48.60% (503,016.79) Aaa / AA+ AAA 3.04 2.93 Aaa / AA+ AAA 3.44 3.28 Aaa / AA+ AAA 1.56 1.51 COMMERCIAL PAPER Sample CUSIP Sample Issuer 2.34% Due 10/15/2018 1,530,000.00 06/14/2018 2.39% Total Commercial Paper 1,530,000.00 2.39% 1,517,867.10 1,517,867.10 1,517,867.10 1,517,867.10 99.21 2.39% 2.39% 1,517,867.10 4,674.15 1,517,867.10 4,674.15 1.98% 0.00 1.98% 0.00 P -1/A-1 NR 0.21 0.21 P -1/A4 NR 0.21 0.21 Chandler Asset Management - CONFIDENTIAL Page 5 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Holdings Report As of Month -end Date CUSIP Security Desertion Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration FOREIGN CORPORATE Sample CUSIP Sample Issuer 2.65% Due 1/5/2022 1,000,000.00 01/29/2018 3.03% 985,980.00 987,758.15 96.91 3.62% 969,083.00 1,913.89 1.27% (18,675.15) Total Foreign Corporate 1,000,000.00 3.03% 985, 980.00 987,758.15 3.62% 969,083.00 1,913.89 1.27% (18,675.15) A2 /A AA- A2/A AA - 3.44 3.23 3.44 3.23 MONEY MARKET FUND Fl Sample CUSIP Sample Issuer MMKT Fund #657 Total Money Market Fund Fl CORPORATE Sample CUSIP Sample Issuer Callable Note Cont 7/2/2018 2.1% Due 8/1/2018 547,678.76 547,678.76 Various 1.55% 1.55% 547,678.76 547,678.76 1.00 1.55% 547,678.76 0.00 0.71% Aaa / AAA 0.00 NR 0.00 0.00 547,678.76 547,678.76 1.55% 547,678.76 0.00 0.71% Aaa/AAA 0.00 NR 0.00 0.00 790,000.00 02/05/2014 2.10% 795,387.80 790,000.00 100.00 2.10% 790,000.00 8,295.00 1.04% Al / A 0.00 AA - 0.00 0.00 Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.95% Due 3/15/2019 Sample CUSIP Sample Issuer 1.7% Due 3/15/2019 Sample CUSP Sample Issuer 1.1% Due 8/8/2019 Sample CUSIP Sample Issuer Cont 10/3/2020, 2.3% Due 11/3/2020 Sample Issuer 2.125% Due 3/1/2019 Sample Issuer 1.95% Due 3/4/2019 750,000.00 900,000.00 900,000.00 570,000.00 890,000.00 11/19/2014 2.07% 1,000,000.00 05/28/2014 1.86% 06/10/2014 2.05% 03/08/2016 1.73% 08/01/2016 1.14% 05/26/2017 2.05% 751,755.00 750,238.80 903,825.00 900,472.90 896,049.00 899,485.64 569,566.80 569,910.59 889,083.30 889,688.57 1,008,120.00 1,005,280.33 99.80 2.47% 99.65 2.55% 99.68 2.48% 99.52 2.49% 98.58 2.52% 98.25 3.10% 748,504.50 6,640.62 896,823.00 7,166.25 0.98% (1,734.30) 1.18% (3,649.90) 897,083.10 6,630.00 567,240.06 3,660.67 877,381.58 4,704.64 982,527.00 5,622.22 1.18% (2,402.54) 0.74% (2,670.53) Al / AA - NR A2 / A A A2 / AA- A Aa2/AA A+ 0.58 0.57 0.59 0.58 0.62 0.61 0.62 0.61 1.15% Aaa / AAA (12,306.99) AA+ 1.02 1.00 1.29% A3 / A (22,753.33) A 2.26 2.17 Chandler Asset Management - CONFIDENTIAL Page 6 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Holdings Report As of Month -end Date CA% CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration CORPORATE Sample CUSIP Sample Issuer 12/23/2020 2.5% Due 1/22/2021 Sample CUSIP Sample Issuer 4/15/2021 2.1% Due 5/16/2021 Sample CUSIP Sample Issuer Cont 4/21/2021 3.25% Due 5/21/2021 Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer Note 3.125% Due 6/23/2021 Sample Issuer 12/23/2021 2.625% Due 1/24/2022 Sample Issuer 3% Due 5/15/2022 Sample Issuer 12/13/2022 2.4% Due 1/13/2023 1,325,000.00 1,000,000.00 350,000.00 815,000.00 900,000.00 500,000.00 02/21/2018 2.90% 1,310,239.50 1,312,445.25 98.19 3.27% 1,301,028.10 828.13 1.70% A2 / A (11,417.15) A+ 2.48 2.37 03/09/2018 2.84% 977,610.00 980,331.54 97.76 2.94% 977,595.00 4,375.00 1.28% Aa2 / AA - (2,736.54) NR 2.79 2.67 05/17/2018 3.25% 349,989.50 349,990.18 06/20/2018 3.13% 04/26/2017 2.44% 05/23/2017 2.30% 814,959.25 814,960.56 907,353.00 905,363.36 516,390.00 512,488.91 Total US Corporate US TREASURY Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.5% Due 1/31/2019 Sample Issuer 1.5% Due 2/28/2019 Sample Issuer 1.625% Due 4/30/2019 Sample Issuer 1.125% Due 5/31/2019 Sample Issuer 1.625% Due 8/31/2019 Sample Issuer 1.5% Due 11/30/2019 1,000,000.00 11,690,000.00 1,850,000.00 1,750,000.00 1,200,000.00 750,000.00 2,000,000.00 1, 200, 000.00 05/09/2018 3.25% 963,260.00 965,023.86 100.15 3.19% 100.23 3.04% 97.70 3.33% 99.75 3.07% 96.64 3.22% 350,539.00 2,180.21 0.46% A2 / A 548.82 A 2.81 2.57 816,892.43 2,405.38 879,306.30 459.38 1.07% Aa2 / AA 1,931.87 AA 2.90 2.74 498, 744.00 3,166.67 966,389.00 1,200.00 1.15% Al/A+ (26,057.06) AA - 0.65% Aa2 / AA (13, 744.91) A+ 1.26% Aa 1 / AA+ 1,365.14 NR 3.49 3.29 3.79 3.53 4.46 4.17 2.37% 11,653,588.15 11,645,680.49 2.85% 11,550,053.07 57,334.17 15.13% Al/AA- (95,627.42) A+ 2.04 1.93 Various 1.41% 03/18/2014 1.55% Various 1.49% 03/18/2016 1.04% 1,855,715.18 1,850,844.32 1,746,041.02 1,749,537.72 1, 207,472.77 1,201,131.81 751,965.40 750,510.73 99.64 2.23% 99.56 2.26% 99.46 2.36% 98.96 2.39% 1,843,351.10 75.40 1,742,343.75 10,985.05 1,193,484.00 4,927.98 742,206.75 1,429.30 2.40% Aaa / AA+ (7,493.22) AAA 2.29% Aaa / AA+ (7,193.97) AAA 1.56% Aaa / AA+ (7,647.81) AAA 0.97% Aaa / AA+ (8,303.98) AAA Various 2,022,287.95 1.27% 2,007,463.77 12/11/2014 1,194, 332.15 1.60% 1,198,481.49 99.07 2.50% 98.62 2.56% 1,981,484.00 13,600.55 1,183,406.40 3,049.18 0.50 0.49 0.58 0.57 0.75 0.74 0.83 0.82 2.60% Aaa / AA+ (25,979.77) AAA 1.08 1.06 1.55% Aaa / AA+ (15,075.09) AAA 1.33 1.31 Chandler Asset Management - CONFIDENTIAL Page 7 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Holdings Report As of Month -end Date CM CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration US TREASURY Sample CUSIP Sample CUSIP Sample Issuer 1.25% Due 1/31/2020 Sample Issuer 1.375% Due 2/29/2020 Sample CUSIP Sample Issuer 1.375% Due 4/30/2020 Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 1,250,000.00 2,000,000.00 1,500,000.00 11/14/2016 1.32% Various 1.22% 1,247,318.64 1, 248, 746.26 2,011,686.39 2,004,889.55 Various 1.34% Sample Issuer 1.5% Due 5/31/2020 Sample Issuer 1.375% Due 9/30/2020 Sample Issuer 1.625% Due 11/30/2020 Sample Issuer 1.375% Due 1/31/2021 Sample Issuer 1.25% Due 3/31/2021 Sample Issuer 1.375% Due 4/30/2021 Sample Issuer 2% Due 5/31/2021 Sample CUSIP Sample Issuer 1.125% Due 7/31/2021 Sample CUSIP Sample CUSIP 1,500,000.00 750,000.00 1,000,000.00 1,250,000.00 1, 000, 000.00 1,000,000.00 1,500,000.00 1, 000, 000.00 Various 1.63% 05/03/2017 1.59% 1,500,883.94 1,500,793.04 1,492,309.71 1,496,600.63 744,758.37 746,669.78 07/25/2017 1.62% 11/14/2016 1.58% 01/30/2018 2.31% 12/27/2017 2.08% 1,000,081.48 1,000,056.76 1,239,750.28 1,243,908.81 967,773.44 972,851.56 977,382.81 981,390.45 01/24/2017 1.83% 12/27/2017 2.11% Sample Issuer 1.125% Due 9/30/2021 1,500,000.00 Sample Issuer 1.875% Due 3/31/2022 1,250,000.00 Various 1.83% 04/20/2018 2.71% 1,510,844.87 1,507,065.91 966,171.88 971,745.39 1,460,042.42 1,467,636.23 1,211,035.16 1,213,744.82 98.04 2.59% 98.09 2.61% 97.84 2.65% 97.94 2.66% 97.25 2.69% 97.52 2.73% 96.72 2.74% 96.17 2.75% 96.37 2.76% 97.95 2.76% 95.28 2.78% 1,225,440.00 42.46 1,961,796.00 11,508.16 1,467,538.50 5,212.29 1,469,062.50 3,811.47 729,345.75 3,465.68 975,234.00 2,752.73 1,209,033.75 46.71 961,680.00 4,200.82 963,672.00 3,493.85 1,469,179.50 5,081.97 1.60% (23,306.26) 2.57% (43,093.55) 1.92% (33,254.54) 1.92% (27,538.13) 0.96% (17,324.03) Aaa / AA+ AAA 1.50 1.47 Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa/AA+ AAA 1.58 1.54 1.75 1.71 1.84 1.79 2.17 2.10 1.27% (24,822.76) 1.58% (34,875.06) 1.26% (11,171.56) 1.26% (17,718.45) Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA 2.34 2.26 2.51 2.43 2.67 2.58 2.75 2.66 95.01 2.78% 96.76 2.81% 952,773.00 30.57 1,425,117.00 5,671.11 1,209,521.25 7,876.54 1.92% (37,886.41) 1.24% (18,972.39) 1.86% (42,519.23) 1.59% (4,223.57) Aaa / AA+ AM Aaa / AA+ AAA 2.84 2.72 3.00 2.92 Aaa / AA+ AAA Aaa / AA+ AAA 3.17 3.06 3.67 3.49 Total US Treasury 25,250,000.00 1.62% 25,107,853.86 25,114,069.03 2.59% 24,705,669.25 32.31% Aaa / AA+ 87,261.82 (408,399.78) AAA 1.84 1.78 TOTAL PORTFOLIO 77,662,678.76 1.76% 77,513,133.27 77,427,515.17 2.63% 76,401,796.03 100.00% Aa 1 / AA+ 325,765.96 (1,025,719.14) AAA 1.71 1.65 TOTAL MARKET VALUE PLUS ACCRUED 76,727,561.99 Chandler Asset Management - CONFIDENTIAL Page 8 Execution Time: 8/21/2018 9:23:32 PM Sample Client Transaction Ledger Account #000000 As of Month -end Date CrAt Transaction Type Settlement Date CUSIP Quantity Security Description Price Acq/Disp Yield Amount Interest Pur/Sold Total Amount Gain/Loss ACQUISITIONS Purchase Purchase Purchase Purchase Purchase Purchase 07/03/2018 Sample CUSIP 2,664.28 Sample Issuer 07/05/2018 Sample CUSIP 13,250.00 Sample Issuer 07/11/2018 Sample CUSIP 07/13/2018 Sample CUSIP 07/17/2018 Sample CUSIP 1,000,000.00 Sample Issuer 16,000.00 Sample Issuer 11,400.00 Sample Issuer Purchase Purchase Purchase Purchase Purchase Purchase 07/20/2018 07/20/2018 07/22/2018 07/24/2018 07/31/2018 07/31/2018 07/31/2018 Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 1,743.75 Sample Issuer 310,000.00 Sample Issuer 16,562.50 Sample Issuer 11,812.50 Sample Issuer 1,000,000.00 Sample Issuer 32,681.35 Sample Issuer 35,906.25 Sample Issuer 1.000 1.000 100.029 1.000 1.000 1.000 1.000 1.000 1.000 97.172 1.000 1.000 1.51% 1.51% 2.74% 1.51% 1.51% 1.51% 1.51% 1.51% 1.51% 2.87% 1.55% 1.55% 2,664.28 0.00 2,664.28 0.00 13,250.00 1,000,290.00 16,000.00 11,400.00 1,743.75 310,000.00 16,562.50 0.00 13,250.00 1,001,512.22 16,000.00 11,400.00 1,743.75 310,000.00 16,562.50 11,812.50 973,164.44 11,812.50 971,720.00 32,681.35 35,906.25 1,222.22 0.00 0.00 0.00 0.00 0.00 0.00 1,444.44 0.00 0.00 0.00 32,681.35 35,906.25 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Subtotal 2,452,020.63 2,424,030.63 2,666.66 2,426,697.29 0.00 TOTAL ACQUISITIONS 2,452,020.63 2,424,030.63 2,666.66 2,426,697.29 0.00 DISPOSITIONS Sale 07/11/2018 Sample CUSIP 1,001,512.22 Sample Issuer 1.000 1.51% 1,001,512.22 0.00 1,001,512.22 0.00 Chandler Asset Management - CONFIDENTIAL Page 9 Execution Time: 8/21/2018 9:23:32 PM DISPOSITIONS Sample Client Account #000000 Transaction Ledger As of Month -end Date ' Om Acq/Disp Yield Amount Interest Pur/Sold Total Amount Gain/Loss Spa (r� 07/31/2018 Sample CUSIP 1,000,000.00 Sample Issuer 1.5% Due 8/31/2018 99.961 1.95% 999,609.38 Subtotal 2,001,512.22 2,001,121.60 Maturity 07/20/2018 Sample CUSIP 310,000.00 Sample Issuer 1.125% Due 7/20/2018 100.000 310,000.00 6,236.41 6,236.41 2,007,358.01 -234.79 0.00 0.00 1,005,845.79 -234.79 Subtotal 310,000.00 310,000.00 310,000.00 0.00 310,000.00 0.00 TOTAL DISPOSITIONS 2,311,512.22 2,311,121.60 6,236.41 2,317,358.01 -234.79 OTHER TRANSACTIONS Interest Interest Interest Interest Interest Interest 07/05/2018 07/13/2018 07/17/2018 07/20/2018 Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Interest Interest Interest 07/22/2018 07/24/2018 07/31/2018 Sample CUSIP 07/31/2018 07/31/2018 Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 1,000,000.00 1,000,000.00 1,520,000.00 310,000.00 1,325,000.00 900,000.00 1,850,000.00 1,250,000.00 1,250,000.00 Sample Issuer 1.375% Due 1/31/2021 Sample Issuer 2.65% Due 1/5/2022 Sample Issuer 2.4% Due 1/13/2023 Sample Issuer 1.5% Due 1/17/2020 Sample Issuer 1.125% Due 7/20/2018 Sample Issuer 2.5% Due 1/22/2021 Sample Issuer 2.625% Due 1/24/2022 Sample Issuer 1.5% Due 1/31/2019 Sample Issuer 1.25% Due 1/31/2020 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 13,250.00 0.00 16,000.00 11,400.00 1,743.75 0.00 0.00 0.00 16,562.50 0.00 11,812.50 0.00 13,250.00 16,000.00 11,400.00 1,743.75 16,562.50 11,812.50 13,875.00 0.00 13,875.00 7,812.50 0.00 7,812.50 8,593.75 0.00 8,593.75 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Chandler Asset Management - CONFIDENTIAL Page 10 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Transaction Ledger As of Monh-end Date CAIR Transaction Settlement Typ'_.. _ . Date CUSIP Quantity Security Descriptionsios Price Acq/Disp Yield Amount Interest Pur/Sold Total Amount Gain/Loss OTHER TRANSACTIONS Interest 07/31/2018 Sample CUSIP 1,000,000.00 Sample Issuer 1.125% Due 7/31/2021 0.000 5,625.00 0.00 5,625.00 0.00 Subtotal Dividend 11,405,000.00 106,675.00 0.00 106,675.00 0.00 07/03/2018 Sample CUSIP 2,194,340.70 Sample Issuer Fund #657 0.000 2,664.28 0.00 2,664.28 0.00 Subtotal 2,194,340.70 2,664.28 0.00 2,664.28 0.00 TOTAL OTHER TRANSACTIONS 13,599,340.70 109,339.28 0.00 109,339.28 0.00 Chandler Asset Management - CONFIDENTIAL Page 11 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Income Earned As of Month -end Date J CUSIP Security Description Trade Date Settle Date Units Book Value: Begin Book Value: Acq Book Value: Disp Book Value: End Prior Accrued Inc. Received Ending Accrued Total Interest Accr. Of Discount Amort. Of Premium Net Accret/Amort Income Earned Total Income FIXED INCOME Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer Callable Note Cont 10/3/2020 2.3% Due 11/03/2020 05/26/2017 05/31/2017 1,000,000.00 1,005,486.49 0.00 0.00 1,005,280.33 Sample Issuer Callable Note Cont 12/13/2022 2.4% Due 01/13/2023 05/09/2018 05/11/2018 1,000,000.00 Sample Issuer Callable Note Cont 7/2/2018 2.1% Due 08/01/2018 02/05/2014 02/10/2014 790,000.00 Sample Issuer N ote 3% Due 05/15/2022 05/23/2017 05/26/2017 500,000.00 964,357.04 0.00 0.00 965,023.86 790,003.37 0.00 0.00 790,000.00 512,768.85 0.00 0.00 512,488.91 3,705.56 0.00 5,622.22 1,916.66 15, 200.00 16,000.00 1,200.00 2,000.00 6,912.50 0.00 8,295.00 1,382.50 0.00 206.16 (206.16) 1,710.50 1,710.50 666.82 0.00 666.82 2,666.82 2,666.82 Sample Issuer N ote 1.7% Due 03/15/2019 03/08/2016 03/15/2016 570,000.00 569,898.33 0.00 0.00 569,910.59 1,916.67 0.00 3,166.67 1,250.00 2,853.17 0.00 3,660.67 807.50 0.00 3.37 (3.37) 1,379.13 0.00 279.94 (279.94) 970.06 12.26 0.00 12.26 819.76 1,379.13 970.06 819.76 Sample Issuer Callable Note Cont 4/15/2021 2.1% Due 05/16/2021 03/09/2018 03/13/2018 1,000,000.00 979,733.19 0.00 0.00 980,331.54 2,625.00 0.00 4,375.00 1,750.00 Sample Issuer N ote 2.125% Due 03/01/2019 11/19/2014 11/24/2014 750,000.00 750,273.72 0.00 0.00 750,238.80 5,312.50 0.00 6,640.62 1,328.12 598.35 0.00 598.35 2,348.35 0.00 34.92 (34.92) 1,293.20 2,348.35 1,293.20 Sample Issuer N ote 1.95% Due 03/04/2019 05/28/2014 05/30/2014 900,000.00 900,541.08 0.00 0.00 900,472.90 5,703.75 0.00 7,166.25 1,462.50 0.00 68.18 (68.18) 1,394.32 1,394.32 Sample Issuer N ote 2.375% Due 03/12/2021 03/26/2018 03/27/2018 2,000,000.00 1,991,653.47 0.00 0.00 1,991,916.15 14,381.94 0.00 18,340.28 3,958.34 262.68 0.00 262.68 4,221.02 4,221.02 Chandler Asset Management - CONFIDENTIAL Page 12 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Income Earned As of Month -end Date CUSIP 4 Security Description Trade Date Settle Date Units Book Value: Begin Book Value: Acq Book Value: Disp Book Value: End Prior Accrued Inc. Received Ending Accrued Total Interest Accr. Of Discount Amort. Of Premium Net Accret/Amort Income Earned Total Income Sample CUSIP Sample Issuer N ote 1.125% Due 06/21/2019 06/28/2016 06/29/2016 1,500,000.00 Sample CUSIP Sample Issuer N ote 1.375% Due 09/28/2020 09/14/2017 09/15/2017 1,500,000.00 Sample CUSIP Sample Issuer N ote 2% Due 09/14/2018 02/07/2014 02/10/2014 1,500,000.00 Sample CUSIP Sample Issuer N ote 1.5% Due 03/08/2019 02/12/2016 02/16/2016 1,500,000.00 Sample CUSIP Sample Issuer N ote 1.875% Due 03/13/2020 05/03/2017 05/04/2017 750,000.00 Sample CUSIP Sample Issuer N ote 1.875% Due 06/11/2021 08/30/2017 08/31/2017 1,250,000.00 1,504,257.06 0.00 0.00 1,503,885.32 1,493,001.53 0.00 0.00 1,493,266.11 1,501,491.27 0.00 0.00 1,500,874.89 1,504,707.66 0.00 0.00 1,504,123.91 753,796.49 0.00 0.00 753,606.97 1,257,348.77 0.00 0.00 1,257,137.05 468.75 0.00 1,875.00 1,406.25 5,328.13 0.00 7,046.88 1,718.75 8,916.66 0.00 11,416.68 2,500.02 7,062.50 0.00 8,937.50 1,875.00 0.00 371.74 (371.74) 1,034.51 1,034.51 264.58 0.00 264.58 1,983.33 0.00 616.38 (616.38) 1,883.64 1,983.33 1,883.64 Sample CUSIP Sample Issuer N ote 1.375% Due 09/13/2019 08/24/2016 08/25/2016 1,500,000.00 1,506,289.44 0.00 0.00 1,505,845.31 4,218.75 0.00 5,390.63 1,171.88 1,302.08 0.00 3,255.21 1,953.13 6,187.50 0.00 7,906.25 1,718.75 0.00 583.75 (583.75) 1,291.25 0.00 189.52 (189.52) 982.36 0.00 211.72 (211.72) 1,741.41 1,291.25 982.36 1,741.41 0.00 444.13 (444.13) 1,274.62 1,274.62 Sample CUSIP Sample Issuer N ote 1.75% Due 06/12/2020 Sample CUSIP Sample Issuer N ote 1.68% Due 10/13/2020 06/15/2017 06/16/2017 1,500,000.00 1,504,469.56 0.00 0.00 1,504,274.96 1,385.42 0.00 3,572.92 2,187.50 0.00 194.60 (194.60) 1,992.90 1,992.90 10/18/2017 10/19/2017 1,500,000.00 1,496,817.04 0.00 0.00 1,496,935.21 5,460.00 0.00 7,560.00 2,100.00 118.17 0.00 118.17 2,218.17 2,218.17 Chandler Asset Management - CONFIDENTIAL Page 13 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Income Earned As of Month -end Date C'A CUSIP Security Description Trade Date Settle Date Units Book Value: Begin Book Value: Acq Book Value: Disp Book Value: End Prior Accrued Inc. Received Ending Accrued Total Interest Accr. Of Discount Amort. Of Premium Net Accret/Amort Income Earned Total Income Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer N ote Due 08/31/2018 09/13/2013 09/16/2013 0.00 999,693.37 0.00 999,844.17 0.00 5,013.59 6,236.41 0.00 1,222.82 150.80 0.00 150.80 1,373.62 1,373.62 Sample Issuer N ote 1.125% Due 07/31/2021 12/27/2017 12/28/2017 1,000,000.00 970,945.49 0.00 0.00 971,745.39 4,692.68 5,625.00 30.57 962.89 799.90 0.00 799.90 1,762.79 1,762.79 Sample Issuer N ote 1.125% Due 05/31/2019 03/18/2016 03/21/2016 750,000.00 Sample Issuer N ote 1.125% Due 09/30/2021 Various Various 1,500,000.00 Sample Issuer N ote 1.875% Due 03/31/2022 04/20/2018 04/23/2018 1,250,000.00 Sample Issuer N ote 2% Due 05/31/2021 01/24/2017 01/25/2017 1,500,000.00 Sample Issuer N ote 1.5% Due 05/31/2020 Various Various 1,500,000.00 750,562.99 0.00 0.00 750,510.73 1,466, 768.34 0.00 0.00 1,467,636.23 1,212,904.82 0.00 0.00 1, 213, 744.82 1,507,277.75 0.00 0.00 1,507,065.91 1,496,443.12 0.00 0.00 1,496,600.63 714.65 0.00 1,429.30 714.65 0.00 52.26 (52.26) 662.39 662.39 4,241.80 0.00 5,671.11 1,429.31 Sample Issuer Note 3.125% Due 06/23/2021 06/20/2018 06/27/2018 815,000.00 814,959.40 0.00 0.00 814,960.56 5,891.39 0.00 7,876.54 1,985.15 2,540.98 0.00 5,081.97 2,540.99 1,905.74 0.00 3,811.47 1,905.73 282.99 0.00 2,405.38 2,122.39 867.89 0.00 867.89 2,297.20 840.00 0.00 840.00 2,825.15 2,297.20 2,825.15 0.00 211.84 (211.84) 2,329.15 2,329.15 157.51 0.00 157.51 2,063.24 2,063.24 1.16 0.00 1.16 2,123.55 2,123.55 Total Fixed Income 75,585,000.00 74,696,988.67 1,972,010.00 1,309,844.17 75,361,969.31 324,967.26 110,244.75 321,091.81 106,369.30 9,005.04 6,190.23 2,814.81 109,184.11 109,184.11 Chandler Asset Management - CONFIDENTIAL Page 14 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Income Earned As of Month -end Date CUSIP Security Description Trade Date Settle Date Units Book Value: Begin Book Value: Acq Book Value: Disp Book Value; End Prior Accrued Inc. Received Ending Accrued T•tal.an -.res Accr. Of Discount Amort. Of Premium Net Accret/Amort ��..-'.! _ - 1'..'. Total Income CASH & EQUIVALENT Sample CUSIP Sample Issuer Government MMKT Fund #657 Various Various 547,678.76 1,097,170.35 452,020.63 1,001,512.22 547,678.76 0.00 2,664.28 0.00 2,664.28 0.00 0.00 0.00 2,664.28 2,664.28 Sample CUSIP Sample Issuer Discount CP 2.34% Due 10/15/2018 06/14/2018 06/15/2018 1.,530,000.00 Total Cash & Equivalent 2,077,678.76 1.,517,867.10 0.00 0.00 1,517,867.10 2,615,037.45 452,020.63 1,001, 512.22 2,065,545.86 1,591.20 0.00 4,674.15 3,082.95 1,591.20 2,664.28 4,674.15 5,747.23 0.00 0.00 0.00 3,082.95 3,082.95 0.00 0.00 0.00 5,747.23 5,747.23 TOTAL PORTFOLIO 77,662,678.76 77,312,026.12 2,424,030.63 2,311,356.39 77,427,515.17 326,558.46 112,909.03 325,765.96 112,116.53 9,005.04 6,190.23 2,814.81 114,931.34 114,931.34 Chandler Asset Management - CONFIDENTIAL Page 15 Execution Time: 8/21/2018 9:23:32 PM Sample Client Cash Flow Report Account #000000 As of Month -end Date , Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 08/01/2018 Interest Sample CUSIP 1,500,000.00 Sample Issuer 1.25% Due 8/1/2019 0.00 9,375.00 08/01/2018 08/08/2018 08/12/2018 Maturity Interest Interest Sample CUSIP 790,000.00 Sample Issuer Callable Note Cont 7/2/2018 790,000.00 8,295.00 Sample CUSIP 890,000.00 Sample Issuer 1.1% Due 8/8/2019 0.00 4,895.00 08/16/2018 08/28/2018 08/31/2018 08/31/2018 08/31/2018 Interest Interest Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 1, 000, 000.00 Sample Issuer 1.125% Due 8/12/2021 0.00 5,625.00 1,000,000.00 Sample Issuer 2.375% Due 2/16/2021 0.00 11,875.00 9,375.00 798,295.00 4,895.00 5,625.00 11,875.00 2,000,000.00 1,750,000.00 2,000,000.00 2,000,000.00 Sample Issuer 1.5% Due 2/28/2020 0.00 15, 000.00 15,000.00 Sample Issuer 1.5% Due 2/28/2019 0.00 13,125.00 Sample Issuer 1.625% Due 8/31/2019 0.00 16,250.00 Sample Issuer 1.375% Due 2/29/2020 0.00 13,750.00 AUG 2018 09/01/2018 Interest Sample CUSIP 750,000.00 Sample Issuer 2.125% Due 3/1/2019 790,000.00 0.00 98,190.00 13,125.00 16,250.00 13,750.00 888,190.00 7,968.75 09/04/2018 09/08/2018 09/12/2018 09/12/2018 09/13/2018 09/13/2018 Interest Interest Interest Interest Interest Interest Sample CUSIP 900,000.00 Sample Issuer 1.95% Due 3/4/2019 0.00 8,775.00 Sample CUSIP Sample CUSIP Sample CUSIP 1,500,000.00 2,000,000.00 1,525,000.00 Sample Issuer 1.5% Due 3/8/2019 0.00 Sample Issuer 2.375% Due 3/12/2021 0.00 Sample Issuer 1.75% Due 9/12/2019 0.00 11,250.00 23,750.00 13,343.75 Sample CUSIP 750,000.00 Sample Issuer 1.875% Due 3/13/2020 0.00 7,031.25 7,968.75 8,775.00 11,250.00 23,750.00 13,343.75 7,031.25 Sample CUSIP 1,500,000.00 Sample Issuer 1.375% Due 9/13/2019 0.00 10,312.50 10,312.50 Chandler Asset Management - CONFIDENTIAL Page 16 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Cash Flow Report As of Month -end Date , Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 09/14/2018 09/15/2018 09/15/2018 09/28/2018 09/30/2018 09/30/2018 Maturity Interest Interest Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 1,500,000.00 900,000.00 570,000.00 Sample Issuer 2% Due 9/14/2018 1,500,000.00 15,000.00 Sample Issuer 1.95% Due 3/15/2019 Sample Issuer 1.7% Due 3/15/2019 0.00 8,775.00 0.00 4,845.00 09/30/2018 09/30/2018 SEP 2018 10/02/2018 10/13/2018 10/13/2018 10/15/2018 10/15/2018 10/30/2018 10/31/2018 10/31/2018 OCT 2018 Interest Interest Interest Interest Interest Interest Sample CUSIP Sample CUSIP 1,500,000.00 1,000,000.00 1,500,000.00 1,250,000.00 750,000.00 Sample Issuer 1.375% Due 9/28/2020 0.00 Sample Issuer 1.25% Due 3/31/2021 0.00 Sample Issuer 1.125% Due 9/30/2021 0.00 Sample Issuer 1.875% Due 3/31/2022 0.00 Sample Issuer 1.375% Due 9/30/2020 0.00 10,312.50 6,250.00 8,437.50 11,718.75 5,156.25 1,515,000.00 8,775.00 4,845.00 10,312.50 6,250.00 8,437.50 11,718.75 5,156.25 Sample CUSIP Maturity Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 2,000,000.00 1,000,000.00 1,500,000.00 2,000,000.00 1,530,000.00 Sample Issuer 1.25% Due 10/2/2019 1,500,000.00 0.00 152,926.25 12,500.00 1,652,926.25 12,500.00 Sample Issuer 2.5% Due 4/13/2021 0.00 12,500.00 Sample Issuer 1.68% Due 10/13/2020 0.00 12,600.00 Sample Issuer 1.125% Due 4/15/2019 Sample Issuer 2.34% Due 10/15/2018 1,000,000.00 Sample Issuer 1.375% Due 4/30/2021 0.00 1,517,867.10 0.00 11,250.00 12,132.90 6,875.00 12,500.00 12,600.00 11,250.00 1,530,000.00 6,875.00 1,500,000.00 Sample Issuer 1.375% Due 4/30/2020 0.00 10,312.50 10,312.50 1,200,000.00 Sample Issuer 1.625% Due 4/30/2019 0.00 9,750.00 9,750.00 1,517,867.10 87,920.40 1,605,787.50 Chandler Asset Management - CONFIDENTIAL Page 17 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Cash Flow Report As of Month -end Date CAlk Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 11/03/2018 Interest Sample CUSIP 1,000,000.00 Sample Issuer 10/3/2020 2.3% Due 11/3/2020 0.00 11,500.00 11,500.00 11/08/2018 11/15/2018 11/16/2018 11/17/2018 Interest Interest Interest Sample CUSIP 11/21/2018 11/27/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 11/30/2018 NOV 2018 Interest Interest Maturity Interest Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP 2,000,000.00 500,000.00 1,000,000.00 Sample Issuer 1.55% Due 5/8/2020 0.00 15,500.00 15,500.00 Sample Issuer 3% Due 5/15/2022 Sample Issuer 4/15/2021 2.1% Due 5/16/2021 Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 12/11/2018 12/12/2018 12/14/2018 Interest Interest Interest Interest Maturity Sample CUSIP Sample CUSIP Sample CUSIP 1,250,000.00 350,000.00 2,000,000.00 750,000.00 1,500,000.00 1,350,000.00 1,200,000.00 1, 000, 000.00 1,500,000.00 Sample Issuer 1.875% Due 11/17/2020 Sample Issuer 4/21/2021 3.25% Due 5/21/2021 Sample Issuer 1.625% Due 11/27/2018 Sample Issuer 1.125% Due 5/31/2019 Sample Issuer 2% Due 5/31/2021 0.00 0.00 0.00 0.00 2,000,000.00 0.00 0.00 7,500.00 7,500.00 10,500.00 10,500.00 11,718.75 11,718.75 Sample Issuer 1.75% Due 5/30/2019 0.00 Sample Issuer 1.5% Due 11/30/2019 0.00 5,655.90 16,250.00 4,218.75 15,000.00 11,812.50 9,000.00 Sample Issuer 1.625% Due 11/30/2020 0.00 8,125.00 Sample Issuer 1.5% Due 5/31/2020 0.00 11,250.00 5,655.90 2,016,250.00 4,218.75 15,000.00 11,812.50 9,000.00 8,125.00 11,250.00 Sample CUSIP 1,250,000.00 Sample Issuer 1.875% Due 6/11/2021 2,000,000.00 0.00 138,030.90 11,718.75 2,138,030.90 11,718.75 Sample CUSIP 1,500,000.00 Sample Issuer 1.75% Due 6/12/2020 0.00 13,125.00 13,125.00 Sample CUSIP 1,000,000.00 Sample Issuer 1.125% Due 12/14/2018 1,000,000.00 5,625.00 1,005,625.00 Chandler Asset Management - CONFIDENTIAL Page 18 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Cash Flow Report As of Month -end Date Rayrnent I ate 12/21/2018 12/22/2018 12/23/2018 Transaction Type CUSIP Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP Quantity Security Description 1,500,000.00 Sample Issuer 1.125% Due 6/21/2019 1,000,000.00 815,000.00 Total Amount Principal Amount 0.00 Income 8,437.50 Sample Issuer 2.75% Due 6/22/2021 0.00 13,520.83 Sample Issuer 3.125% Due 6/23/2021 0.00 12,451.39 8,437.50 13,520.83 12,451.39 DEC 2018 01/05/2019 01/05/2019 01/13/2019 01/17/2019 01/22/2019 01/24/2019 01/31/2019 01/31/2019 01/31/2019 01/31/2019 Interest Interest Interest Interest Interest Interest Interest Interest Interest Maturity Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 1,000,000.00 1,000,000.00 1,000,000.00 Sample Issuer Cont 12/13/2022 2.4% Due 1/13/2023 1,520,000.00 1,325,000.00 900,000.00 1,250,000.00 1,000,000.00 1,250,000.00 Sample Issuer 2% Due 1/5/2022 1,000,000.00 0.00 64,878.47 1,064,878.47 Sample Issuer 2.65% Due 1/5/2022 Sample Issuer 1.5% Due 1/17/2020 Sample Issuer Cont 12/23/2020 2.5% Due 1/22/2021 Sample Issuer 12/23/2021 2.625% Due 1/24/2022 Sample Issuer 1.375% Due 1/31/2021 Sample Issuer 1.125% Due 7/31/2021 Sample Issuer 1.25% Due 1/31/2020 Sample CUSIP 1,850,000.00 Sample Issuer 1.5% Due 1/31/2019 JAN 2019 02/01/2019 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1,850,000.00 1,850,000.00 10,000.00 13,250.00 12,000.00 11,400.00 16,562.50 11,812.50 8,593.75 5,625.00 7,812.50 13,875.00 10,000.00 13,250.00 12,000.00 11,400.00 16,562.50 11,812.50 8,593.75 5,625.00 7,812.50 1,863,875.00 02/08/2019 02/12/2019 Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP 1,500,000.00 890,000.00 1,000,000.00 Sample Issuer 1.125% Due 8/12/2021 Sample Issuer 1.25% Due 8/1/2019 0.00 110,931.25 9,375.00 1,960,931.25 9,375.00 Sample Issuer 1.1% Due 8/8/2019 0.00 0.00 4,895.00 5,625.00 4,895.00 5,625.00 Chandler Asset Management - CONFIDENTIAL Page 19 Execution Time: 8/21/2018 9:23:32 PM Sample Client Cash Flow Report it Account #000000 As of Month -end Date C'A Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 02/16/2019 Interest Sample CUSIP 02/28/2019 02/28/2019 02/28/2019 02/28/2019 FEB 2019 Interest Interest Sample CUSIP Sample CUSIP 1,000,000.00 2,000,000.00 2,000,000.00 Sample Issuer 2.375% Due 2/16/2021 0.00 11,875.00 Sample Issuer 1.625% Due 8/31/2019 0.00 16,250.00 Sample Issuer 1.375% Due 2/29/2020 0.00 13, 750.00 11,875.00 16,250.00 13,750.00 Interest Maturity Sample CUSIP 2,000,000.00 Sample Issuer 1.5% Due 2/28/2020 0.00 15,000.00 15,000.00 Sample CUSIP 1,750,000.00 Sample Issuer 1.5% Due 2/28/2019 1,750,000.00 13,125.00 1,763,125.00 03/01/2019 03/04/2019 03/08/2019 03/12/2019 03/12/2019 03/13/2019 Maturity Maturity Maturity Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 750,000.00 900,000.00 1,500,000.00 2, 000, 000.00 Sample Issuer 2.125% Due 3/1/2019 1,750,000.00 750,000.00 89,895.00 7,968.75 1,839,895.00 757,968.75 Sample Issuer 1.95% Due 3/4/2019 Sample Issuer 1.5% Due 3/8/2019 Sample Issuer 2.375% Due 3/12/2021 Sample CUSIP 03/13/2019 03/15/2019 03/15/2019 03/28/2019 03/31/2019 Interest Maturity Maturity Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP 1,525,000.00 750,000.00 1,500,000.00 Sample Issuer 1.75% Due 9/12/2019 Sample Issuer 1.875% Due 3/13/2020 900,000.00 1,500,000.00 0.00 0.00 0.00 8,775.00 11,250.00 23,750.00 13,343.75 7,031.25 908,775.00 1,511,250.00 23,750.00 Sample Issuer 1.375% Due 9/13/2019 0.00 Sample CUSIP Sample CUSIP 570,000.00 900,000.00 1,500,000.00 Sample Issuer 1.7% Due 3/15/2019 570,000.00 Sample Issuer 1.95% Due 3/15/2019 Sample Issuer 1.375% Due 9/28/2020 Sample CUSIP 750,000.00 Sample Issuer 1.375% Due 9/30/2020 900,000.00 0.00 0.00 10,312.50 4,845.00 8,775.00 13,343.75 7,031.25 10,312.50 574,845.00 908,775.00 10,312.50 10,312.50 5,156.25 5,156.25 Chandler Asset Management - CONFIDENTIAL Page 20 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Cash Flow Report As of Month -end Date iiayment Date Transaction Type CUSIP 03/31/2019 03/31/2019 03/31/2019 MAR 2019 Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP Quantity Security Description 1,500,000.00 1,000,000.00 1,250,000.00 Sample Issuer 1.125% Due 9/30/2021 Principal Amount 0.00 Sample Issuer 1.25% Due 3/31/2021 0.00 Sample Issuer 1.875% Due 3/31/2022 0.00 04/02/2019 04/13/2019 04/13/2019 04/15/2019 04/30/2019 04/30/2019 04/30/2019 Interest Interest Interest Maturity Interest Interest Maturity Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 2,000,000.00 1,000,000.00 1,500,000.00 2,000,000.00 1,500,000.00 1,000,000.00 1,200,000.00 Sample Issuer 1.25% Due 10/2/2019 4,620,000.00 0.00 Income 8,437.50 6,250.00 11,718.75 137,926.25 Calk Total Amount 8,437.50 6,250.00 11,718.75 4,757,926.25 Sample Issuer 2.5% Due 4/13/2021 Sample Issuer 1.68% Due 10/13/2020 Sample Issuer 1.125% Due 4/15/2019 Sample Issuer 1.375% Due 4/30/2020 Sample Issuer 1.375% Due 4/30/2021 0.00 0.00 2,000,000.00 0.00 0.00 12, 500.00 12,500.00 12,600.00 11,250.00 Sample Issuer 1.625% Due 4/30/2019 1,200,000.00 10,312.50 6,875.00 9,750.00 12,500.00 12,500.00 12,600.00 2,011,250.00 10,312.50 6,875.00 1,209,750.00 APR 2019 05/03/2019 3,200,000.00 Interest Sample CUSIP 1,000,000.00 Sample Issuer 10/3/2020 2.3% Due 11/3/2020 0,00 75,787.50 11,500.00 3,275,787.50 11,500.00 05/08/2019 05/15/2019 05/16/2019 05/17/2019 Interest Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP 2,000,000.00 Sample Issuer 1.55% Due 5/8/2020 0.00 500,000.00 Sample Issuer 3% Due 5/15/2022 0.00 1,000,000.00 Sample Issuer 4/15/2021 2.1% Due 5/16/2021 0.00 1,250,000.00 Sample Issuer 1.875% Due 11/17/2020 0.00 15,500.00 7,500.00 10,500.00 11,718.75 15,500.00 7,500.00 10,500.00 11,718.75 Chandler Asset Management - CONFIDENTIAL Page 21 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Cash Flow Report As of Month -end Date ____ Payment Date Transaction Type CUSIP Quantity Security Description Principal Amount Income Total Amount 05/21/2019 05/30/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 05/31/2019 MAY 2019 Interest Maturity Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP 350,000.00 1,350,000.00 1, 000, 000.00 Sample Issuer Cont 4/21/2021 3.25% Due 5/21/2021 0.00 5,687.50 5,687.50 Sample Issuer 1.75% Due 5/30/2019 1,350,000.00 11,812.50 1,361,812.50 Sample Issuer 1.625% Due 11/30/2020 0.00 8,125.00 8,125.00 Interest Maturity Sample CUSIP Sample CUSIP Sample CUSIP 1,200,000.00 Sample Issuer 1.5% Due 11/30/2019 0.00 9,000.00 9,000.00 1,500,000.00 Sample Issuer 2% Due 5/31/2021 0.00 15,000.00 15,000.00 1,500,000.00 Sample Issuer 1.5% Due 5/31/2020 0.00 11,250.00 11,250.00 Sample CUSIP 750,000.00 Sample Issuer 1.125% Due 5/31/2019 750,000.00 4,218.75 754,218.75 06/11/2019 06/12/2019 06/21/2019 06/22/2019 06/23/2019 JUN 2019 Interest Interest Maturity Sample CUSIP Sample CUSIP Sample CUSIP 1,250,000.00 Sample Issuer 1.875% Due 6/11/2021 2,100,000.00 0.00 121,812.50 11, 718.75 2,221,812.50 11,718.75 1, 500, 000.00 Sample Issuer 1.75% Due 6/12/2020 1,500,000.00 Sample Issuer 1.125% Due 6/21/2019 Interest Interest Sample CUSIP 1,000,000.00 Sample Issuer 2.75% Due 6/22/2021 0.00 1,500,000.00 0.00 13,125.00 13,125.00 8,437.50 1,508,437.50 Sample CUSIP 815,000.00 Sample Issuer 3.125% Due 6/23/2021 0.00 1,500,000.00 13,750.00 12,734.38 59,765.63 13,750.00 12,734.38 07/05/2019 07/05/2019 07/13/2019 07/17/2019 Interest Interest Sample CUSIP 1,000,000.00 Sample Issuer 2% Due 1/5/2022 0.00 10,000.00 1,559,765.63 10,000.00 Sample CUSIP 1, 000, 000.00 Sample Issuer 2.65% Due 1/5/2022 0.00 13,250.00 Interest Interest Sample CUSIP 1,000,000.00 Sample Issuer 12/13/2022 2.4% Due 1/13/2023 0.00 12,000.00 Sample CUSIP 1,520,000.00 Sample Issuer 1.5% Due 1/17/2020 0.00 11,400.00 13,250.00 12,000.00 11,400.00 Chandler Asset Management - CONFIDENTIAL Page 22 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Cash Flow Report As of Month -end Date Pay ent Date Transaction Type CUSIP 07/22/2019 07/24/2019 07/31/2019 07/31/2019 07/31/2019 Interest Interest Interest Interest Interest Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Quantity Security Description 1,325,000.00 Sample Issuer 12/23/2020 2.5% Due 1/22/2021 Principal Amount 0.00 CAIL Income 16,562.50 Total Amount 16,562.50 900,000.00 1,250,000.00 1,000,000.00 1,250,000.00 Sample Issuer 12/23/2021 2.625% Due 1/24/2022 0.00 Sample Issuer 1.375% Due 1/31/2021 0.00 Sample Issuer 1.125% Due 7/31/2021 0.00 Sample Issuer 1.25% Due 1/31/2020 0.00 JUL 2019 TOTAL 0.00 21,827,867.10 11,812.50 8,593.75 5,625.00 7,812.50 97,056.25 11,812.50 8,593.75 5,625.00 7,812.50 97,056.25 1,235,120.40 23,062,987.50 Chandler Asset Management - CONFIDENTIAL Page 23 Execution Time: 8/21/2018 9:23:32 PM Sample Client Account #000000 Important Disclosures Cat Chandler Asset Management, Inc. ("Chandler") is an SEC registered investment adviser. For additional information about our firm, please see our current disclosures (Form ADV). To obtain a copy of our current disclosures, you may contact your client service representative by calling the number on the front of this statement or you may visit our website at www.chandlerasset.com. Information contained in this monthly statement is confidential and is provided for informational purposes only and should not be construed as specific investment or legal advice. The information contained herein was obtained from sources believed to be reliable as of the date of this statement, but may become outdated or superseded at any time without notice. Custody: Your qualified custodian bank maintains control of all assets reflected in this statement and we urge you to compare this statement to the one you receive from your qualified custodian. Chandler does not have any authority to withdraw or deposit funds from/to the custodian account. Valuation: Prices are provided by IDC, an independent pricing source. In the event IDC does not provide a price or if the price provided is not reflective of fair market value, Chandler will obtain pricing from an alternative approved third party pricing source in accordance with our written valuation policy and procedures. Our valuation procedures are also disclosed in Item 5 of our Form ADV Part 2A. Performance: Performance results are presented gross -of -advisory fees and represent the client's Total Return. The deduction of advisory fees lowers performance results. These results include the reinvestment of dividends and other earnings. Past performance may not be indicative of future results. Therefore, clients should not assume that future performance of any specific investment or investment strategy will be profitable or equal to past performance levels. All investment strategies have the potential for profit or loss. Economic factors, market conditions or changes in investment strategies, contributions or withdrawals may materially alter the performance and results of your portfolio. Source ice Data Indices, LLC ("ICE"), used with permission. ICE PERMITS USE OF THE ICE INDICES AND RELATED DATA ON AN "AS IS" BASIS; ICE, ITS AFFILIATES AND THEIR RESPECTIVE THIRD PARTY SUPPLIERS DISCLAIM ANY AND ALL WARRANTIES AND REPRESENTATIONS, EXPRESS AND/OR IMPLIED, INCLUDING ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE, INCLUDING THE INDICES, INDEX DATA AND ANY DATA INCLUDED IN, RELATED TO, OR DERIVED THEREFROM. NEITHER ICE DATA, ITS AFFILIATES OR THEIR RESPECTIVE THIRD PARTY PROVIDERS GUARANTEE THE QUALITY, ADEQUACY, ACCURACY, TIMELINESS OR COMPLETENESS OF THE INDICES OR THE INDEX DATA OR ANY COMPONENT THEREOF, AND THE INDICES AND INDEX DATA AND ALL COMPONENTS THEREOF ARE PROVIDED ON AN "AS IS" BASIS AND LICENSEE'S USE IS AT LICENSEE'S OWN RISK. ICE DATA, ITS AFFILIATES AND THEIR RESPECTIVE THIRD PARTY DO NOT SPONSOR, ENDORSE, OR RECOMMEND CHANDLER, OR ANY OF ITS PRODUCTS OR SERVICES. Index returns assume reinvestment of all distributions. Historical performance results for investment indexes generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment management fee, the incurrence of which would have the effect of decreasing historical performance results. It is not possible to invest directly in an index. Ratings: Ratings information have been provided by Moody's, S&P and Fitch through data feeds we believe to be reliable as of the date of this statement, however we cannot guarantee its accuracy. Chandler Asset Management - CONFIDENTIAL Page 24 Execution Time: 8/21/2018 9:23:32 PM INVESTMENT REPORT CIALlk CHANDLER ASSET MANAGEMENT Sample Client Quarterly Report Period Ending September 30, 2018 Please note: This sample client service report is being provided for illustrative purposes to demonstrate Chandler Asset Management's reporting capabilities. References to specific securities and their characteristics are examples of securities held in the portfolio and are not intended to be, and should not be interpreted as an offer, solicitation or recommendation to purchase or sell any financial instrument, an indication that the purchase of such securities was or will be profitable, or representative of the composition or performance of the portfolio. The information contained in this sample presentation was obtained from sources we believe to be reliable as of the date of publication, but we do not guarantee its accuracy. This presentation contains the current opinions of the author, which are subject to change without notice. Any statements concerning financial market trends or future forecasts are based on current market conditions, which will fluctuate. Past performance is not indicative of future success. Fixed income investments are subject to interest, credit and market risk. Interest rate risk: the value of fixed income investments will decline as interest rates rise. Credit risk: the possibility that the borrower may not be able to repay interest and principal. Low rated bonds generally have to pay higher interest rates to attract investors willing to take on greater risk. Market risk: the bond market in general could decline due to economic conditions, especially during periods of rising interest rates. CHANDLER ASSET MANAGEMENT, INC. I 800.317.4747 I www.chandlerasset.com Table of Contents SECTION 1 SECTION 2 SECTION 3 SECTION 4 SECTION 5 Economic Update Account Profile Portfolio Holdings Transactions Disclosures *Please see the d►sclosures on front page of th►s presentat►on CAM Section 1 I Economic Update CA Economic Update As expected, the Federal Open Market Committee (FOMC) voted to raise the fed funds target rate by 25 basis points to a range of 2 00%-2 25% at the September 26th meeting The vote was unanimous, including a vote from the new Board of Governors Vice Chair, Richard Clarida The Fed raised its median forecast for GDP growth in 2018 and 2019 and left its forecasts for unemployment and inflation relatively unchanged The Fed also kept its fed funds rate forecasts unchanged with the exception of the longer -run target which increased slightly to 3 0% The Fed's forecast points to one more fed funds rate hike this year and three more hikes next year Once again, in its policy statement, the FOMC noted that economic activity has been rising at a "strong rate" and policymakers expect that further gradual increases in the fed funds rate will be appropriate The FOMC continues to believe risks to the economic outlook are roughly balanced Market participants believe there is a very high probability that there will be another rate hike in December Economic data remains favorable but predictive economic indicators suggest that economic growth is unlikely to accelerate Although the labor market is strong and consumer confidence is high, we do not believe the economy is close to overheating The Core PCE Index suggests that inflation is in line with the Fed's 2 0% target Market participants are forecasting annualized GDP growth of about 3 0% in the third quarter, 2 8% in the fourth quarter, and 2 5% next year Treasury yields increased in September At month -end, the 2 -year Treasury yield was up 19 basis points to 2 82%, while the 10 -year Treasury yield was up 20 basis points to 3 06% The spread between 2- and 10 -year Treasury yields remained narrow at just 24 basis points at month -end Over the past 20 years, the average spread between 2- and 10 -year Treasuries has been about 140 basis points We foresee an upward bias to rates across the Treasury yield curve but believe that the yield curve will remain quite flat over the intermediate -term *Please see the disclosures on front page of this presentation CAM Employment MOM Change In (000's) 350 300 250 200 150 100 50 0 Nonfarm Payroll (000's) 1/0 16 16 1> 1> I> 1> 1� 19 4 Source: US Department of Labor 12.0% 11.0% 10.0% 9.0% 8.0% 7.0% 6.0% 5.0% 4.0% 3.0% 2.0% Unemployment Rate Underemployment Rate (U6) Unemployment Rate (U3) +O 16 ok 16, 1> 1> 1> 1 j 19 49 eve Source: US Deportment of Labor U.S. payrolls rose by 201,000 in August, above the consensus forecast of 190,000. June and July payrolls were revised down by a total of 50,000. On a trailing 3 -month and 6 -month basis payrolls increased by an average of 185,000 and 192,000 per month, respectively, more than enough to absorb new entrants into the labor market. The unemployment rate was unchanged from the prior month at 3.9%. The labor participation rate declined to 62.7% in August from 62.9% in July. A broader measure of unemployment called the U-6, which includes those who are marginally attached to the labor force and employed part time for economic reasons, declined to 7.4% in August from 7.5% in July. Wages rose 0.4% in August on a month -over -month basis, slightly higher than expectations. Wages were up 2.9% on a year -over -year basis in August, versus up 2.7% year -over -year in July. The average workweek was unchanged at 34.5 hours. *Please see the disclosures on front page of this presentation. CA Inflation 3.5% 3.0% 2.5% a) c4 c s 2.0% u 1.5% >- >- 1.0% 0.5% 0.0% Consumer Price Index (CPI) asins CP I YOY % Change Core CPI YOY% Change e.„6,lc9 4 Source: US Department of Labor YOY( %) Change 3.5% 3.0% 2.5% 2.0% 1.5% 1.0% 0.5% 0.0% Personal Consumption Expenditures (PCE) PCE Price Deflator YOY % Change PCE Core Deflator YOY % Change 046 ci& � 16 16 6) ,l 1� 1 1> 1;4531e Source: US Department of Commerce The Consumer Price Index (CPI) was up 2.7% year -over -year in August, versus up 2.9% year -over -year in July. Core CPI (CPI less food and energy) was up 2.2% year -over -year in August, down from 2.4% year -over -year in July. The Personal Consumption Expenditures (PCE) index was up 2.2% year -over -year in August, down slightly from 2.3% year -over -year in July. Core PCE (excluding food and energy) was up 2.0% on a year -over -year basis in August, unchanged from 2.0% in July. Core PCE inflation, which is the Fed's primary inflation gauge, remains in line with the Fed's 2.0% target. *Please see the disclosures on front page of this presentation. c. i Consumer 8.0% 7.0% 6.0% a) c 5.0% Ct u 4.0% O 3.0% >- 2.0% 1.0% 0.0% Retail Sales YOY % Change -14,6c.‘/1/0 � 6b '2S S /fr°� ��b mod` ��'� .16 .16. 1j l .jj jj I5) 9 Ic? 145 140 135 130 125 a 120 � 115 m 110 105 100 95 90 85 Consumer Confidence 0,0 ok 0f 16 00 16, > V> 1> > lj 1> /x, c? 1� 1(9 c9 1d, Source: US Department of Commerce Source: The Conference Board On a year -over -year basis, retail sales were up 6.6% in August, versus up 6.7% year -over -year in July. On a month -over -month basis, retail sales increased just 0.1% in August, following an upwardly revised increase of 0.7% in July. Strong sales in July were somewhat offset by softer trends in August, but the overall pace of consumer spending in the third quarter appears solid. The Consumer Confidence Index remains very strong at 138.4 in September, up from 134.7 in August. Ongoing strength in the labor market continues to support consumer confidence and spending trends. *Please see the disclosures on front page of this presentation. CAt; Economic Activity MOM ( %) Change 1.4% 1.2% 1.0% 0.8% 0.6% 0.4% 0.2% 0.0% -0.2% Leading Economic Indicators (LEI) #4‹�` � ea �`. S . 4°ld So d`. 16 16. 1> 1 j 1> a 1� 4 Source: The Conference Board 14 0.60 0.40 a) 0.20 L J Q 0.00 c 2 M -0.20 -0.40 -0.60 Chicago Fed National Activity Index (CFNAI) Source: Federal Reserve Bank of Chicago The Index of Leading Economic Indicators (LEI) rose 0.4% month -over -month in August, following a 0.7% increase in July. According to the Conference Board, the index points to solid US economic growth for the remainder of the year. However, the Conference Board also warns that industrial companies that are more sensitive to business cycles should prepare for a possible moderation in economic growth next year. The Chicago Fed National Activity Index (CFNAI) was unchanged month -over -month in August at 0.18, suggesting that economic activity remains steady. On a 3 -month moving average basis, the index increased to 0.24 in August from 0.02 in July. *Please see the disclosures on front page of this presentation. IHousing 1800 Housing Starts 1600 I a Multi Family Housing Starts a Single Family Housing Starts O 1400 N 1200 0 1000 s F- 800 a) C 600 co v 400 200 YOY(%) Change 7.5% 7.0% 6.5% 6.0% 5.5% 5.0% 0 4.5% -9c 4/°i ��b 1%-n le. °� 16 16 `lam 1> 1j 16) 1� 1(5) S&P/CaseShiller 20 City Composite Home Price Index Source: US Department of Commerce Source: S&P; Please see the disclosures at the end of this presentation. Total housing starts increased 9.2% in August. Single-family starts increased 1.9% in August while multi -family starts surged 29%. However, permits fell 5.7% in August. According to the Case-Shiller 20 -City home price index, home prices were up 5.9% year -over -year in July, versus 6.4% in June. Housing data tends to be volatile on a month -over -month basis. Broadly speaking, the housing sector is facing a few different headwinds including supply constraints, rising mortgage interest rates, and a shortage of skilled labor, and housing trends have softened. *Please see the disclosures on front page of this presentation. CA i Manufacturing 62 60 58 56 54 52 50 48 46 Institute of Supply Management Purchasing Manager Index Contracting 16 16 1 j 1� 1� 1� `1sz9 'l? A1a Source: Institute for Supply Management YOY( %) Change 6.0% 5.0% 4.0% 3.0% 2.0% 1.0% 0.0% - 1.0% - 2.0% -3.0% Industrial Production /fro ea 16 16 1> (z) S /i/ok e, 1> 1> 1j 1� 1� 1c9 Source: Federal Reserve The Institute for Supply Management (ISM) manufacturing index edged down to 59.8 in September from 61.3 in August (the highest level since May 2004). A reading above 50.0 suggests the manufacturing sector is expanding. The Industrial Production index was up 4.9% year -over -year in August versus up 4.0% year -over -year in July. On a month -over -month basis, the manufacturing component of the index edged up just 0.2% in August, following a 0.3% increase in July, pointing to modest growth in the sector. Capacity Utilization increased to 78.1% in August from 77.9% in July, but remains below the long -run average of 79.8% indicating there is still excess capacity for growth. *Please see the disclosures on front page of this presentation. i Personal Consumption Expenditures Gross Domestic Product (GDP) Components of GDP 9/17 12/17 3/18 6/18 1.5% 2.6% 0.4% 2.6% Gross Private Domestic Investment 1.5% 0.1% 1.6% -0.1% Net Exports and Imports 0.0% -0.9% 0.0% 1.2% Federal Government Expenditures -0.1% 0.3% 0.2% 0.2% State and Local (Consumption and Gross Investment) -0.1% 0.2% 0.1% 0.2% Total 2.8% 2.3% 2.2% 4.2% Source: US Department of Commerce 6.0% 5.0% 4.0% 3.0% 2.0% 1.0% 0.0% -1.0% -2.0% Gross Domestic Product (GDP) or GDP QOQ%Change GDP YOY % Change c.1 '�.1' c,1 '�.1 c.1 �.1 c,1 O.1 c,c 1 1 '�1] '1 '7,1 lc) Q Q S S 6' 6 Source: US Department of Commerce Annualized second quarter GDP grew at an annualized pace of 4.2%, according to the third estimate, following growth of 2.2% in the first quarter. Consumer spending and exports were particularly strong in the second quarter. Market participants estimate the economy grew 3.0% in the third quarter. GDP growth is expected to ease back toward the 2.5%-3.0% range in the fourth quarter. *Please see the disclosures on front page of this presentation. CAS Bond Yields US Treasury Note Yields 4.0% 4.0% 3.5% 3.5% 3.0% 1.5% 1.0% 0.5% 0.0% 2 -Year 5 -Year 10 -Year e 4i0 %76%‘1 1> 1� 16) 4 Source: Bloomberg 3.0% 1.5% 1.0% 0.5% 0.0% US Treasury Yield Curve Sep -18 Jun -18 Sep -17 C s a 1 4io co Jr `t Et O`r Source: Bloomberg On a year -over -year basis, Treasury yields have increased and the Treasury yield curve has flattened. The spread between 2 -Year and 10 -year Treasury yields has narrowed from 85 basis points to 24 basis points, year -over -year as of September month -end. Rate hikes by the Federal Reserve have put upward pressure on rates, while supply and demand imbalances, technical factors, and subdued inflation expectations have contributed to the curve flattening. *Please see the disclosures on front page of this presentation. i Objectives As of September 30, 2018 Investment Objectives The investment objectives of the Client are first, to provide safety of principal to ensure the preservation of capital in the overall portfolio; second, to provide adequate liquidity to meet all requirements that may be reasonably anticipated; and third, to earn a commensurate rate of return. Chandler Asset Management Performance Objective The performance objective for the Client is to earn a return that equals or exceeds the return on an index of 1-3 Year Treasury notes. Strategy In order to achieve these objectives, we invest in high quality fixed income securities consistent with the Client's investment policy and state legal requirements. *Please see the disclosures on front page of this presentation. CA Compliance Category Treasury Issues Agency Issues Supranationals Municipal Issues As of September 30, 2018 Sample Client Assets managed by Chandler Asset Management are in full compliance with State law and the Client's investment policy. Banker's Acceptances Commercial Paper Negotiable CDs Non -Negotiable CDs Medium Term Notes Asset -Backed (ABS), Mortgage -Backed Securities; Pass-Throughs; CMOs Money Market Mutual Funds and Mutual Funds Repurchase Agreements Rev. Repo Agreements LAI F LA County Pool Prohibited Credit Quality Max Per Issuer Maximum maturity Standard No Limit No Limit "AN' rated or better by a NRSRO; 20% maximum; 10% max per issuer; Issued by IBRD, IFC or IADB only "A" rated or equivalent by a NRSRO; 30% maximum; 5% max per issuer "A-1" rated or equivalent by a NRSRO; "A" rated issuer or equivalent by a NRSRO, if the bank has senior debt outstanding; 40% maximum; 5% max per issuer; 180 days max maturity "A-1" rated or equivalent by a NRSRO; "A" rated issuer or equivalent by a NRSRO, if any long-term debt; 25% maximum; 5% max per issuer; 270 days max maturity; Entity organized and operating in the U.S. and has total assets >$500 million "A-1" short-term rated or "A" long-term rated issuer or equivalent by a NRSRO and having assets in excess of $10 billion; 30% maximum (combined NCDs, CDs); 5% max per issuer; 2 years max maturity 30% maximum (combined NCDs, CDs); 5% max per issuer; Collateralized or FDIC Insured; 2 years max maturity "A" rated or equivalent by a NRSRO; 30% maximum; 5% max per issuer; Issued by corporations organized and operating within the U.S. or by depository institutions licensed by the U.S. "AAA" rated or equiv by a NRSRO; "A" rated issuer by a NRSRO; 20% max (combined mortgage -backed and asset - backed, MPTs, CMOs); 5% max per issuer Highest rating or "AAA" rated by two NRSROs; SEC registered adviser with AUM >$500 million and experience greater than 5 years; 10% per one Mutual Fund; 20% maximum in Money Market Mutual Funds; 20% maximum combined of total portfolio in these securities "A-1" or equivalent short term rating; "A" rated long term issuer or equivalent; 30 days max maturity; Not used by IA 10% maximum; 30 days max maturity; Not used by IA Comment Complies Complies Complies Complies Pursuant to California Govt Code Section 16429.1; Not used by IA 5% max; Not used by IA Derivative structures such as Range Notes, Dual Index Notes, Inverse floaters, Interest -only strips from mortgaged backed securities; Zero interest accrual securities; Orange County Pool The City shall not purchase any security rated "Al" and/ or "A+" or below if that security has been placed on "credit watch" for a possible downgrade by a NRSRO. 5% of portfolio (except U.S. government issuers, Supranationals, investment pools, Mutual Funds, and Money Market Funds) 5 years Complies Complies Complies Complies Complies Complies Complies Complies Complies Complies Complies Complies Complies Complies Complies *Please see the disclosures on front page of this presentation. CM Portfolio Characteristics Sample Client As of September 30, 2018 Benchmark* 9/30/2018 6/30/2018 Portfolio Portfolio Average Maturity (yrs) Average Modified Duration Average Purchase Yield Average Market Yield Average Quality** Total Market Value 1.85 1.78 n/a 2.85% AAA 1.87 1.69 1.92% 2.90% AA/Aa1 195,727,630 1.82 1.64 1.78% 2.67% AA/Aa2 194,921,818 *ICE BAML 1-3 Yr US Treasury Index **Benchmark is a blended rating of S&P, Moody's, and Fitch. Portfolio is S&P and Moody's respectively. *Please see the disclosures on front page of this presentation. CA Sector Distribution Sample Client Corporate 23.9% US Treasury 21.4% September 30, 2018 ABS 6.4% Agency 39.1% US Treasury 20.2% Corporate 24.5% Supranational 4.0% Negotiable CD 5.1% Money Market Fund Fl 0.1% *Please see the disclosures on front page of this presentation. Supranational 5.1% June 30, 2018 Negotiable CD 5.1% As of September 30, 2018 ABS 6.7% Money Market Fund Fl 0.1% Agency 38.2% CAT Duration Allocation 30% 25% 20% 15% 10% 5% 0% Sample Client As of September 30, 2018 ■ ABS ■ Agency ■ Corporate Money Market Fund Fl ■ Negotiable CD ■ Supranational ■ US Treasury 0-0.25 Years 0.25-0.5Years 0.5-1Years 1-2Years 2-3Years 3-4Years 4-5Years 5+Years 0-0.25 0.25-0.50 0.50-1 1-2 2-3 3-4 4-5 5+ 09/30/18 2.7% 5.9% 25.3% 28.0% 18.5% 19.6% 0.0% 0.0% *Please see the disclosures on front page of this presentation. A c i Portfolio Allocation & Duration Changes Sample Client Agency Corporate US Treasury ABS Negotiable CD Supranational Portfolio Allocation 1 Mar Money Market I 0.1% Fund Fl 0.0% 110.0% 105.0% 100.0% 95.0% 90.0% 85.0% 80.0% 107.1% 6.6% 6.9% 5.1% 5.1% 5.1% 5.1% 100.5% ■ 21.5% 20.3% 23.7% 24.3% Duration as a % of the Benchmark 95.1% 94.6% 98.2% 91.9% 91.9% As of September 30, 2018 38.0% 38.2% ■ 9/30/2018 ■ 6/30/2018 95.7% 12/31/2016 3/31/2017 6/30/2017 9/30/2017 12/31/2017 3/31/2018 6/30/2018 9/30/2018 Benchmark: ICE BAML 1-3 Yr US Treosury Index *Please see the disclosures on front page of this presentation. CM Issuers Sample Client As of September 30, 2018 Issue Name Investment Type % Portfolio Sample Government Issuer Sample Government Agency Sample Government Agency Sample Government Agency Sample Corporate Issuer Sample Supranational Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Government Agency Sample Corporate Issuer Sample Supranational Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer *Please see the disclosures on front page of this presentation. US Treasury Agency Agency Agency ABS Supranational Corporate ABS Corporate Agency Corporate Supranational Corporate Corporate Corporate Corporate Corporate Corporate Supranational Corporate Corporate Corporate Corporate ABS Corporate Corporate Negotiable CD Negotiable CD Negotiable CD ABS ABS Corporate Negotiable CD Corporate Corporate Corporate Negotiable CD Negotiable CD 21.44% 14.11% 12.32% 11.28% 1.60% 1.60% 1.59% 1.48% 1.41% 1.38% 1.37% 1.30% 1.25% 1.24% 1.23% 1.20% 1.18% 1.16% 1.14% 1.13% 1.06% 1.03% 1.02% 1.01% 1.00% 1.00% 0.88% 0.88% 0.87% 0.83% 0.83% 0.78% 0.77% 0.76% 0.76% 0.75% 0.64% 0.64% CAt Issuers Sample Client As of September 30, 2018 Issue Name Investment Type % Portfolio Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Corporate Issuer Sample Money Market Fund Sample Corporate Issuer ABS Corporate Corporate Corporate Negotiable CD Corporate Corporate Corporate Corporate Corporate Money Market Fund Fl Corporate 0.63% 0.62% 0.60% 0.50% 0.44% 0.32% 0.25% 0.25% 0.23% 0.12% 0.07% 0.06% TOTAL 100.00% *Please see the disclosures on front page of this presentation. CA Quality Distribution 80.0% 70.0% 60.0% 50.0% 40.0% 30.0% 20.0% 10.0% 0.0% Sample Client September 30, 2018 vs. June 30, 2018 AAA AA ■ 9/30/2018 A As of September 30, 2018 6/30/2018 <A NR AAA AA A <A NR 9/30/18 6/30/18 Source: S&P Ratings 7.3% 67.8% 21.0% 0.0% 4.0% 8.5% 65.8% 21.6% 0.0% 4.1% *Please see the disclosures on front page of this presentation. CM i Investment Performance 0.12% 0.10% 0.08% 0.06% 0.04% 0.02% 0.00% 12 months TOTAL RATE OF RETURN Sample Client ICE BAML 1-3 Yr US Treasury Index Sample Client Total Rate of Return Annualized Since Inception 03/31/1991 2 years ■ Sample Client 3 years 3 months 12 months o/ 5 years 10 years ICE BAML 1-3 Yr US Treasury Index Annualized As of September 30, 2018 Since Inception 2 years 3 years % % �0 °/ 0 0/ ° 5 years 10 years % 0/0 Since Inception Total rate of return: A measure of a portfolio's performance over time. It is the internal rate of return, which equates the beginning value of the portfolio with the ending value; it includes interest earnings, realized and unrealized gains and losses in the portfolio. *Please see the disclosures on front page of this presentation. Cir. Section 3 I Portfolio Holdings CM Holdings Report Sample Client As of September 30, 2018 USIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Market Value Mkt YTM Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration ABS Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.500% Due 10/15/2019 Sample Issuer 1.470% Due 01/15/2020 Sample Issuer 1.590% Due 04/15/2020 Sample Issuer 1.560% Due 05/15/2020 Sample Issuer 1.140% Due 08/17/2020 Sample Issuer 1.560% Due 09/15/2020 Sample Issuer 2.100% Due 10/15/2020 Sample Issuer 2.420% Due 10/15/2020 Sample Issuer 1.320% Due 01/15/2021 Sample Issuer 1.730% Due 02/16/2021 Sample Issuer 1.700% Due 06/15/2021 Sample Issuer 1.720% Due 07/21/2021 Sample Issuer 1.780% Due 08/16/2021 Sample Issuer 1.760% Due 08/16/2021 Sample Issuer 1.680% Due 08/16/2021 Sample Issuer 1.820% Due 10/15/2021 Sample Issuer 2.050% Due 11/22/2021 23,106.49 71,158.62 201,555.76 534,686.88 130,734.33 131,820.82 2,022,496.59 1,150,000.00 1,380,296.57 220,000.00 259,354.25 375,854.11 700, 000.00 380,000.00 875,000.00 250,000.00 485,000.00 02/22/2017 1.50% 03/21/2017 1.47% 07/11/2017 1.60% 08/16/2017 1.57% 08/01/2016 1.14% 03/22/2016 1.58% 01/23/2018 2.12% 02/21/2018 2.44% Various 1.82% 03/07/2017 1.74% 01/24/2017 1.71% 03/21/2017 1.73% 03/21/2017 1.81% 03/22/2017 1.77% 06/20/2017 1.69% 07/11/2017 1.83% 11/22/2017 2.07% 23,106.40 23,106.46 71,158.25 71,158.46 201,538.24 201,546.48 534,665.86 534,675.04 130,730.83 130,732.77 131,795.25 131,810.09 2,022,289.89 2,022,347.21 1,149,949.75 1,149,962.63 1,370,161.13 1,372,638.42 219,974.11 219,984.87 259,331.58 259,340.66 375,831.74 375,840.02 699,640.58 699,771.24 379,969.26 379,980.43 874,924.31 874,948.96 249,981.70 249,987.26 484,931.66 484,947.50 99.94 5.94% 99.87 2.79% 99.75 2.73% 99.68 2.76% 99.33 2.77% 99.59 2.79% 99.66 2.82% 99.80 2.85% 99.17 2.95% 99.21 2.99% 99.19 3.08% 99.02 3.08% 99.22 3.04% 98.83 3.07% 98.65 3.08% 98.59 3.13% 98.72 3.10% 23,093.70 15.40 71,068.24 46.49 201,044.53 142.43 532,966.77 370.72 129,864.42 66.24 131,285.36 91.40 2,015,710.97 1,887.66 1,147,664.35 1,236.89 1,368,819.20 202.44 218,272.78 169.16 257,260.48 195.96 372,189.53 179.57 694,569.40 553.78 375,565.40 278.67 863,198.00 653.33 246,469.25 202.22 478, 778.91 276.18 0.01% (12.76) 0.04% (90.22) 0.10% (501.95) 0.27% (1,708.27) 0.07% (868.35) 0.07% (524.73) 1.03% (6,636.24) 0.59% (2,298.28) 0.70% (3,819.22) 0.11% (1,712.09) 0.13% (2,080.18) 0.19% (3,650.49) 0.36% (5,201.84) 0.19% (4,415.03) 0.44% (11,750.96) 0.13% (3,518.01) 0.24% (6,168.59) Aaa/NR AAA Aaa/NR AAA Aaa/NR AAA Aaa / NR AAA Aaa / AAA N R Aaa / AAA N R Aaa / AAA N R Aaa/NR AAA Aaa/NR AAA Aaa / AAA N R Aaa/NR AAA Aaa/NR AAA Aaa/NR AAA NR / AAA AAA Aaa / AAA N R Aaa/NR AAA Aaa / NR AAA 0.96 0.03 1.21 0.10 1.46 0.22 1.54 0.27 1.80 0.41 1.88 0.33 1.96 0.47 1.96 0.48 2.21 0.51 2.30 0.63 2.62 0.59 2.72 0.72 2.79 0.62 2.79 0.89 2.79 0.97 2.96 1.09 3.06 1.23 *Please see the disclosures on front page of this presentation. GM Holdings Report Sample Client As of September 30, 2018 CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Gain/Loss Fitch Maturity Duration Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP TOTAL ABS Sample Issuer 1.770% Due 01/18/2022 Sample Issuer 1.930% Due 01/18/2022 Sample Issuer 1.990% Due 03/15/2022 Sample Issuer 3.010% Due 05/18/2022 Sample Issuer 2.950% Due 08/22/2022 735,000.00 540,000.00 675,000.00 750,000.00 670,000.00 12,561,064.42 08/09/2017 1.79% 11/07/2017 1.94% 11/14/2017 2.00% 05/22/2018 3.03% 08/21/2018 2.98% 2.04% 734,872.62 734,907.46 539,950.21 539,961.67 674,947.62 674,959.07 749,983.65 749,985.40 669,908.08 669,912.19 12,549,642.72 12,552,504.29 98.36 3.08% 98.26 3.16% 98.72 3.19% 99.68 3.19% 99.52 3.19% 3.00% 722,916.60 578.20 530,618.04 376.35 666,341.10 597.00 747,636.00 815.21 666,793.38 549.03 12,462,126.41 9,484.33 0.37% (11,990.86) 0.27% (9,343.63) 0.34% (8,617.97) 0.38% (2,349.40) 0.34% (3,118.81) 6.37% (90,377.88) Aaa / AAA NR Aaa / AAA NR Aaa / AAA NR NR/AAA AAA Aaa/NR AAA Aaa / AAA Aaa 3.22 1.26 3.22 1.43 3.37 1.08 3.55 1.99 3.81 2.13 2.58 0.87 Agency Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.290% Due 11/19/2018 Sample Issuer 1.000% Due 02/26/2019 Sample Issuer 1.500% Due 03/08/2019 Sample Issuer 1.125% Due 04/15/2019 Sample Issuer 1.750% Due 05/30/2019 Sample Issuer 1.625% Due 06/14/2019 Sample Issuer 1.125% Due 06/21/2019 Sample Issuer 1.150% Due 07/01/2019 Sample Issuer 0.875% Due 07/19/2019 Sample Issuer 1.250% Due 08/01/2019 Sample Issuer 0.875% Due 08/02/2019 1,000,000.00 2,275,000.00 1,700,000.00 3,225,000.00 275,000.00 1,750,000.00 3,130,000.00 1,700,000.00 5,550,000.00 1,700,000.00 2,335,000.00 03/03/2016 1.07% 06/27/2016 0.78% 02/09/2016 0.99% Various 1.13% 05/13/2016 0.99% 06/23/2016 1.01% 06/02/2016 1.14% 04/26/2016 1.15% Various 0.99% Various 1.36% 07/29/2016 0.93% 1,005,970.00 1,000,108.55 2,287,876.50 2,276,549.95 1,726,214.00 1, 702, 967.18 3,224,332.25 3,224,900.53 281,270.00 276,187.29 1,781,465.00 1,756,525.00 3,128,685.40 3,129,725.98 1,700,136.00 1,700,028.40 5,532,705.00 5,545,619.83 1,692,427.40 1,698,663.07 99.95 2.21% 99.54 2.45% 99.68 2.42% 99.36 2.54% 99.52 2.58% 99.41 2.60% 99.07 2.60% 99.07 2.57% 98.76 2.63% 98.95 2.67% 999,533.00 5,805.00 2,264,532.73 4,107.64 1,694,502.20 3,754.17 3,204,366.45 1,612.50 273,677.25 2,018.58 1,739,601.50 10,822.05 3,100,831.53 12,715.63 1,684,125.40 6,516.67 5,481,307.65 13,759.38 1,682,172.10 5,312.50 0.51% (575.55) 1.16% (12,017.22) 0.87% (8,464.98) 1.64% (20,534.08) 0.14% (2,510.04) 0.89% (16,923.50) 1.59% (28,894.45) 0.86% (15,903.00) 2.81% (64,312.18) 0.86% (16,490.97) 2,331,077.20 2,334,018.40 98.67 2.67% 2,303,932.83 5,051.06 1.18% (30,085.57) Aaa / AA+ AM Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA 0.05 0.05 0.32 0.32 0.35 0.35 0.45 0.45 0.58 0.57 0.62 0.61 0.64 0.63 0.67 0.66 0.72 0.71 0.75 0.74 0.75 0.74 *Please see the disclosures on front page of this presentation. GM i Holdings Report Sample Client As of September 30, 2018 CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.375% Due 08/15/2019 Sample Issuer 1.000% Due 08/28/2019 Sample Issuer 1.250% Due 10/02/2019 Sample Issuer 1.000% Due 10/24/2019 Sample Issuer 1.375% Due 11/15/2019 Sample Issuer 1.250% Due 12/13/2019 Sample Issuer 1.500% Due 01/17/2020 Sample Issuer 1.500% Due 02/28/2020 Sample Issuer 1.375% Due 04/20/2020 Sample Issuer 1.750% Due 06/12/2020 Sample Issuer 1.500% Due 07/30/2020 Sample Issuer 1.875% Due 12/11/2020 Sample Issuer 3.000% Due 10/12/2021 Sample Issuer 2.000% Due 01/05/2022 Sample Issuer 2.250% Due 03/11/2022 Sample Issuer 2.750% Due 06/10/2022 Sample Issuer 3.125% Due 09/09/2022 Sample Issuer 2.500% Due 12/09/2022 1,330,000.00 3,000,000.00 1,700,000.00 4, 685, 000.00 4,695,000.00 1, 300, 000.00 5,390,000.00 4,110, 000.00 07/18/2017 1.45% 09/01/2016 1.08% 02/22/2016 1.20% Various 1.48% 1,328,044.90 1,329,258.77 5, 215, 000.00 750,000.00 2,795,000.00 4,000,000.00 650,000.00 1, 600, 000.00 1,300,000.00 3, 000, 000.00 3,750,000.00 1,750,000.00 Various 1.57% 07/18/2016 1.07% Various 1.52% Various 1.58% Various 1.59% 05/23/2017 1.59% Various 1.52% 01/17/2018 2.20% 10/22/2018 3.05% 09/27/2017 1.90% 09/15/2017 1.81% Various 2.86% 09/25/2018 3.01% 08/27/2018 2.80% 2,992,620.00 2,997,968.81 1,703,026.00 1,700,769.71 4,627,508.05 4,663,269.62 4,668,708.10 4,685,655.20 1,307,865.00 1,302,577.34 5,386,222.80 5,388,416.57 4,100,117.06 4,105,777.72 5,184, 283.40 5,198,834.97 753,637.50 751,921.51 2,793,152.80 2,793,917.32 3,963,840.00 3,973,649.00 649,044.50 649,052.43 1,606,304.00 1,604,691.63 1,324,271.00 1,318,210.68 2,987,747.50 2,988,759.74 3,765,750.00 3,765,357.34 1,729,000.00 1,729,872.76 98.99 2.68% 98.64 2.69% 98.64 2.75% 98.31 2.76% 98.58 2.77% 98.35 2.76% 98.48 2.79% 98.30 2.81% 97.94 2.82% 98.22 2.89% 97.69 2.86% 97.74 2.99% 99.89 3.04% 96.93 3.02% 97.49 3.04% 98.99 3.05% 100.16 3.08% 97.85 3.06% 1,316,553.70 3,860.69 2,959,233.00 5,250.00 1,676,959.90 1,711.81 4,605,659.54 910.97 4,628,509.41 29,767.61 0.67% (12,705.07) 1,278,548.70 6,229.17 5,307,888.74 23,356.67 4,040,187.54 10,788.75 5,107,435.41 2,191.03 736,626.00 5,067.71 2,730,457.86 10,597.71 3,909,456.00 29,166.67 649, 259.65 1,029.17 1,550,928.00 10,311.11 1,267,401.20 4,062.50 2,969,823.00 39,187.51 3,756,180.00 16,927.08 1,712,401.25 17,256.94 1.51% (38,735.81) 0.86% (23,809.81) 2.35% (57,610.08) 2.38% (57,145.79) 0.66% (24,028.64) 2.72% (80,527.83) 2.07% (65,590.18) 2.61% (91,399.56) 0.38% (15,295.51) 1.40% (63,459.46) 2.01% (64,193.00) 0.33% 207.22 0.80% (53,763.63) 0.65% (50,809.48) 1.54% (18,936.74) 1.93% (9,177.34) 0.88% (17,471.51) Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ NR Aaa / AA+ AAA Aaa / AA+ NR Aaa/AA+ NR Aaa / AA+ AAA Aaa / AA+ NR Aaa / AA+ NR Aaa / AA+ AAA Aaa / AA+ NR 0.79 0.78 0.82 0.81 0.92 0.90 0.98 0.96 1.04 1.01 1.12 1.09 1.21 1.18 1.33 1.30 1.47 1.44 1.62 1.57 1.75 1.70 2.12 2.03 2.95 2.80 3.18 3.03 3.36 3.20 3.61 3.36 3.86 3.59 4.11 3.83 *Please see the disclosures on front page of this presentation. CM Holdings Report Sample Client As of September 30, 2018 CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Market Value % of Port. Moody/S&P Mkt YTM Accrued Int. Gain/Loss Fitch Maturity Duration Sample CUSIP Sample Issuer 2.375% Due 01/19/2023 1, 600, 000.00 10/04/2018 3.10% TOTAL Agency 77,260,000.00 1.59% 1,554,000.00 1,554,792.60 77,117,301.36 77,148,047.90 97.33 3.05% 2.77% 1,557,241.60 10,766.67 76,189,333.14 299,914.95 0.80% 2,449.00 39.08% (958,714.76) Aaa / AA+ AAA Aaa / AA+ Aaa 4.22 3.95 1.49 1.43 Corporate Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.300% Due 11/03/2018 Sample Issuer 1.700% Due 02/19/2019 Sample Issuer 1.700% Due 02/22/2019 Sample Issuer 1.700% Due 03/15/2019 Sample Issuer 2.125% Due 04/22/2019 Sample Issuer 2.200% Due 04/25/2019 Sample Issuer 1.400% Due 05/20/2019 Sample Issuer 1.100% Due 08/08/2019 Sample Issuer 1.300% Due 08/15/2019 Sample Issuer 2.300% Due 09/11/2019 Sample Issuer 1.400% Due 09/20/2019 Sample Issuer 2.250% Due 10/08/2019 Sample Issuer 2.125% Due 10/28/2019 Sample Issuer 1.800% Due 10/30/2019 485,000.00 380,000.00 1,060,000.00 320,000.00 500,000.00 1,050,000.00 1,000,000.00 1,000,000.00 1, 215, 000.00 1,300,000.00 1,225,000.00 250,000.00 250,000.00 245,000.00 10/29/2015 1.33% 02/16/2016 1.70% 02/16/2016 1.71% 03/08/2016 1.73% 09/13/2016 1.51% 01/22/2016 1.91% 05/17/2016 1.45% 08/01/2016 1.14% Various 1.25% Various 1.97% Various 1.39% 12/06/2016 1.81% 12/06/2016 1.86% 10/23/2017 1.84% 484,515.00 484,999.11 379,954.40 379,995.42 1,059,819.80 1,059,981.40 319,756.80 319,970.24 507,860.00 501,426.08 1,059,324.00 1,051,164.49 998,600.00 999,744.29 998,970.00 999,736.62 1,216,847.45 1,215,489.53 1,313,226.00 1, 303, 203.68 1,225,368.25 1,225,109.30 253,052.50 251,007.65 251,772.50 250,573.51 244,808.90 244,904.97 99.99 2.85% 99.65 2.87% 99.67 2.75% 99.66 2.61% 99.66 2.86% 99.74 2.75% 99.24 2.80% 98.77 2.73% 98.82 2.82% 99.41 2.99% 98.77 2.81% 99.36 2.94% 99.41 2.73% 98.84 2.99% 484,957.81 3,117.47 378,662.40 1,292.00 1,056,496.70 3,403.78 318,921.60 695.11 498,285.50 265.63 1,047,226.95 385.00 992,390.00 6,261.11 987,672.00 2,536.11 1,200,718.89 3,334.50 1,292,363.80 4,152.77 1,209,947.20 1,953.20 248,408.75 359.38 248,530.00 44.27 242,154.57 12.25 0.25% (41.30) 0.19% (1,333.02) 0.54% (3,484.70) 0.16% (1,048.64) 0.25% (3,140.58) 0.54% (3,937.54) 0.51% (7,354.29) 0.51% (12,064.62) 0.62% (14,770.64) 0.66% (10,839.88) 0.62% (15,162.10) 0.13% (2,598.90) 0.13% (2,043.51) 0.12% (2,750.40) Aaa / AAA AA+ Aa3 /AA- A+ Aa 1 / AA+ NR Aa2 /AA A+ A2 /A- A+ A1 /A+ AA- Aa3 /AA- A+ Aaa / AAA AA+ Aa2 / AA A+ Al/A AA - Al / AA - NR Al/AA- A Al/AA- AA- A2 /A A 0.01 0.01 0.30 0.30 0.31 0.31 0.37 0.37 0.47 0.47 0.48 0.48 0.55 0.54 0.77 0.76 0.79 0.77 0.86 0.84 0.89 0.87 0.94 0.92 0.99 0.98 1.00 0.98 *Please see the disclosures on front page of this presentation. CM Holdings Report Sample Client As of September 30, 2018 CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price MktYTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 5.000% Due 12/10/2019 Sample Issuer 1.900% Due 01/27/2020 Sample Issuer 1.900% Due 02/07/2020 Sample Issuer 2.200% Due 03/03/2020 Sample Issuer 1.800% Due 05/05/2020 Sample Issuer 1.800% Due 06/05/2020 Sample Issuer 2.550% Due 08/18/2020 Sample Issuer 1.850% Due 09/04/2020 Sample Issuer 2.200% Due 12/14/2020 Sample Issuer 2.550% Due 01/08/2021 Sample Issuer 2.150% Due 02/01/2021 Sample Issuer 2.650% Due 02/05/2021 Sample Issuer 2.800% Due 03/01/2021 Sample Issuer 2.500% Due 04/15/2021 Sample Issuer 3.000% Due 05/11/2021 Sample Issuer 2.150% Due 05/18/2021 1,000,000.00 1,635,000.00 1,400,000.00 495,000.00 125,000.00 1,500,000.00 2,000,000.00 645,000.00 1,000,000.00 500,000.00 450,000.00 700, 000.00 1,000,000.00 1, 500, 000.00 2,000,000.00 1,200,000.00 12/06/2016 1.90% 02/01/2017 1.91% 02/03/2017 1.92% 02/28/2017 2.24% 05/02/2017 1.91% 05/24/2017 1.82% Various 2.14% 09/05/2017 1.88% 12/28/2016 2.25% 03/20/2018 2.93% 10/23/2017 2.17% 02/22/2018 2.81% 02/26/2018 2.73% 09/05/2017 1.99% 06/07/2018 3.13% 07/26/2017 2.06% 1,090,000.00 1,033,175.18 1,634,329.65 1,634,721.51 1,399,314.00 1,399,709.41 494,485.20 494,770.78 124,601.25 124,799.53 1,499,130.00 1,499,538.01 2,028,696.00 2,014,046.00 644,458.20 644,666.39 998,080.00 998,968.72 494,925.00 496,036.24 449,793.00 449,857.32 696,815.00 697,549.77 1,002,060.00 1,001,598.05 1,525,950.00 1, 517, 468.29 1,992,500.00 1,993,507.04 102.15 3.01% 98.53 3.12% 98.72 2.94% 98.68 3.21% 98.03 3.14% 98.04 3.07% 98.96 3.15% 97.79 3.10% 97.97 3.20% 1,203,924.00 1,202,628.26 1,021,524.00 19,583.33 1,610,931.17 8,111.42 1,382,085.60 6,206.67 98.59 3.22% 97.42 3.35% 98.45 3.37% 98.73 3.37% 98.00 3.35% 99.30 3.29% 97.56 3.16% 488,483.82 1,754.50 122,542.00 1,100.00 1,470,639.00 10,950.00 1,979,198.00 10,341.66 630,721.64 1,889.31 979,692.00 8,372.22 492,925.50 4,002.08 438,367.95 2,418.75 689,152.10 4,431.39 987,334.00 4,666.67 1,469,944.50 1,666.67 1,985,900.00 28,333.33 1,170, 692.40 11,681.67 0.53% (11,651.18) 0.83% (23,790.34) 0.71% (17,623.81) 0.25% (6,286.96) 0.06% (2,257.53) 0.76% (28,899.01) 1.02% (34,848.00) 0.32% (13,944.75) Aa3 / AA - NR Al/A A Aa 1 / AA+ NR A2/A- A Al/A+ A+ A2/A A Al/A AA- A3/A A 0.50% Al / A+ (19,276.72) NR 0.25% (3,110.74) 0.23% (11,489.37) 0.35% (8,397.67) 0.51% (14,264.05) 0.75% (47,523.79) 1.03% (7,607.04) 0.60% Aa3 / A+ (31,935.86) A+ A2/A A A2 / A- A+ Al/A A Al/A+ NR Al/A AA- A2/A+ NR 1.11 1.06 1.24 1.21 1.27 1.23 1.34 1.30 1.51 1.46 1.60 1.54 1.80 1.73 1.85 1.79 2.12 2.03 2.19 2.09 2.26 2.16 2.27 2.16 2.33 2.23 2.46 2.35 2.53 2.38 2.55 2.43 *Please see the disclosures on front page of this presentation. CM i Holdings Report Sample Client As of September 30, 2018 CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 3.250% Due 05/21/2021 Sample Issuer 4.250% Due 05/24/2021 Sample Issuer 2.400% Due 06/07/2021 Sample Issuer 1.650% Due 07/12/2021 Sample Issuer 3.150% Due 08/09/2021 Sample Issuer 2.550% Due 12/09/2021 Sample Issuer 3.375% Due 12/10/2021 Sample Issuer 2.625% Due 01/24/2022 Sample Issuer 2.450% Due 02/15/2022 Sample Issuer 2.625% Due 02/17/2022 Sample Issuer 2.500% Due 05/15/2022 Sample Issuer 2.700% Due 01/06/2023 Sample Issuer 2.700% Due 01/11/2023 TOTAL US Corporate 2,385,000.00 1,000,000.00 1,500,000.00 2,000,000.00 2,105,000.00 1,000,000.00 500,000.00 1,000,000.00 2,000,000.00 1,735,000.00 2,000,000.00 1,500,000.00 1,000,000.00 47,155,000.00 Various 3.09% 04/27/2018 3.03% 09/07/2018 3.24% 06/28/201.8 3.14% 08/06/2018 3.16% 11/17/2017 2.40% 10/03/2018 3.39% 01/24/2018 2.72% 05/15/2018 3.26% Various 2.99% 06/07/2018 3.17% 07/24/2018 3.38% 09/07/2018 3.33% 2.46% 2,395,533.45 2,393,997.40 1,035,570.00 1,029,694.60 1,467,315.00 1,468,981.94 1,914,160.00 1,923,835.38 2,104, 347.45 2,104,397.46 1,005,530.00 1,004, 213.33 499,760.00 499,764.56 996,280.00 996,991.36 1, 943, 080.00 1,950,059.97 1, 713, 723.60 1,715,143.28 1,950,780.00 1,955,688.27 1,458,270.00 1,460,786.64 974,710.00 975,524.78 47,051,996.40 46,969,425.76 99.67 3.39% 102.34 3.29% 97.42 3.44% 95.65 3.35% 99.66 3.28% 97.46 3.42% 99.87 3.42% 97.39 3.48% 97.00 3.42% 97.05 3.58% 96.79 3.47% 96.80 3.53% 96.70 3.55% 3.20% 2,377,036.49 34,234.69 1,023,414.00 18,534.72 1,461,345.00 14,40a00 1,912,942.00 9,991.67 2,097,836.69 15,103.38 974,568.00 10,058.33 499,344.50 984.38 973,927.00 7,072.92 1,939,986.00 10,344.44 1, 683, 749.84 9,361.78 1,935,816.00 23,055.56 1,452,025.50 12,937.50 967,043.00 8,250.00 46,425,903.87 327,651.62 1.23% (16,96a91) 0.53% (6,280.60) 0.75% (7,636.94) 0.98% (10,893.38) 1.08% (6,560.77) 0.50% (29,645.33) 0.26% (420.06) 0.50% (23,064.36) 1.00% (10,073.97) A2/A A Aa3 / AA - N R A2/A- AA- A2/A+ N R A1 /A+ N R A2/A A+ A2/A+ NR A1 /A+ AA- A2/A N R 0.87% A2 /A (31,393.44) A+ 1.00% Al / AA - (19,872.27) A 0.75% A2 /A (8,761.14) A 0.50% Aa3 / AA - (8,481.78) A+ 23.89% Al / A+ (543,521.89) A+ 2.56 2.40 2.56 2.38 2.60 2.47 2.70 2.59 2.78 2.62 3.11 2.92 3.11 2.92 3.24 3:04 3.30 3.11 3.30 3.10 3.54 3.31 4.19 3.87 4.20 3.89 2.14 2.02 Money Market Fund Fl Sample CUSIP Sample Issuer TOTAL Money Market Fund Fl 128,119.11 128,119.11 Various 2.03% 2.03% 128,119.11 128,119.11 128,119.11 128,119.11 1.00 2.03% 2.03% 128,119.11 0.00 128,119.11 0.00 0.07% 0.00 0.07% 0.00 Aaa / AAA AAA Aaa / AAA Aaa 0.00 0.00 0.00 0.00 *Please see the disclosures on front page of this presentation. CAS Holdings Report Sample Client As of September 30, 2018 CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price MktYTM Market Value Accrued Int. • % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration Negotiable CD Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.760% Due 11/30/2018 1,500,000.00 04/21/2017 1.68% Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.890% Due 01/10/2019 Sample Issuer 1.880% Due 02/07/2019 Sample Issuer 1.910% Due 04/05/2019 Sample Issuer 2.050% Due 05/03/2019 Sample Issuer 1.840% Due 08/02/2019 Sample Issuer 2.070% Due 09/25/2019 TOTAL Negotiable CD Supranational Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample Issuer 1.875% Due 10/07/2019 Sample Issuer 1.625% Due 05/12/2020 Sample Issuer 1.561% Due 09/12/2020 Sample Issuer 2.125% Due 11/09/2020 Sample Issuer 2.250% Due 01/25/2021 TOTAL Supranational 1,250,000.00 1,250,000.00 1,700,000.00 1,700,000.00 1,725,000.00 865,000.00 9,990,000.00 865,000.00 01/10/2017 1.89% 02/08/2017 1.88% 04/05/2017 1.91% 05/03/2017 2.05% 08/03/2017 1.86% 09/25/2017 2.07% 1.90% 1,501,920.00 1,500,094.69 1,250,000.00 1,250,000.00 1,250,000.00 1,250,000.00 1,700,000.00 1,700,000.00 1,700,000.00 1, 700, 000.00 99.95 2.31% 1,499,289.00 11,073.33 0.77% (805.69) Al/A+ AA- 0.08 0.08 1,724,327.25 1,724,746.79 865,000.00 865,000.00 9,991,247.25 9,989,841.48 100.00 1.89% 99.91 2.20% 99.67 2.68% 99.73 2.58% 99.39 2.65% 100.00 2.07% 2.39% 1,250,000.00 7,481.25 1,248,891.25 5,483.33 1, 694, 340.70 2,435.25 1,695,486.50 17,618.61 1,714,444.73 8,023.17 865,000.00 1,840.29 9,967,452.18 53,955.23 0.64% 0.00 0.64% (1,108.75) 0.87% (5,659.30) 0.88% (4,513.50) 0.88% (10,302.06) 0.44% 0.00 5.12% (22,389.30) Aa2 / AA - NR A1 /A+ AA- Aa2 /A+ NR Al/A A Aa3/A+ AA - P -1 / A-1 F-1 Aa3/A+ AA- 0.19 0.20 0.27 0.27 0.43 0.43 0.50 0.50 0.75 0.75 0.90 0.90 0.44 0.43 1,455,000.00 1,730,000.00 1,700,000.00 2,250,000.00 8,000,000.00 09/2 //2017 1.60% 04/05/2017 1.70% 09/12/2017 1.64% 10/02/2017 1.81% Various 2.35% 1.89% 869,6/1.00 867,151.95 1,451,551.65 1,453,291.14 1,725,848.00 1,727,403.57 1,715,757.48 1,710,341.72 2,243,535.00 2,245,184.75 8,006,363.13 8,003,373.13 99.12 2.84% 98.06 2.93% 97.39 3.01% 98.33 2.98% 98.35 3.02% 2.97% 857,391.46 1,081.25 1,426,822.47 11,099.43 1,684,912.74 3,675.72 1,671,645.70 17,259.72 2,212,967.25 13,500.00 7,853,739.62 46,616.12 0.44% (9,760.49) 0.73% (26,468.67) 0.86% (42,490.83) 0.86% (38,696.02) 1.14% (32,217.50) 4.04% (149,633.51) Aaa / AAA AAA Aaa / AAA AAA Aaa/NR AAA Aaa / AAA AAA Aaa / AAA NR Aaa / AAA Aaa 0.93 0.92 1.53 1.48 1.87 1.81 2.03 1.94 2.24 2.15 1.84 1.78 US Treasury Sample CUSIP Sample CUSIP US Treasury Note 1.250% Due 04/30/2019 US Treasury Note 1.125% Due 05/31/2019 1,700,000.00 1,600,000.00 Various 1.22% 12/07/2016 1.22% 1,701,599.45 1,700,220.41 1,596,130.36 1,599,096.80 99.39 2.48% 99.18 2.55% 1,689,706.50 58.70 1,586,937.60 7,573.77 0.86% (10,513.91) 0.81% (12,159.20) Aaa / AA+ AAA Aaa / AA+ AAA 0.50 0.49 0.58 0.57 *Please see the disclosures on front page of this presentation. CA Holdings Report Sample Client As of September 30, 2018 CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price Mkt YTM Market Value Accrued Int. % of Port. Moody/S&P Maturity Gain/Loss Fitch Duration Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP US Treasury Note (1875% Due 07/31/2019 US Treasury Note 1.000% Due 11/30/2019 US Treasury Note 1.125% Due 12/31/2019 US Treasury Note 1.250% Due 01/31/2020 US Treasury Note 1.375% Due 02/29/2020 US Treasury Note 1.125% Due 03/31/2020 US Treasury Note 1.500% Due 06/15/2020 US Treasury Note 1.375% Due 09/30/2020 US Treasury Note 1.375% Due 10/31/2020 US Treasury Note 1.125% Due 06/30/2021 US Treasury Note 1.125% Due 09/30/2021 US Treasury Note 2.000% Due 10/31/2021 US Treasury Note 1.750% Due 11/30/2021 US Treasury Note 1.500% Due 01/31/2022 US Treasury Note 1.875% Due 01/31/2022 US Treasury Note 1.875% Due 02/28/2022 US Treasury Note 1.875% Due 03/31/2022 US Treasury Note 1.750% Due 06/30/2022 1,725,000.00 1,750,000.00 550,000.00 1,900,000.00 1,200,000.00 1,200,000.00 1,345,000.00 2,525,000.00 3,000,000.00 4,000,000.00 1,000,000.00 2,000,000.00 1,750,000.00 1,800,000.00 1,800,000.00 3,000,000.00 3,000,000.00 3,500,000.00 09/29/2015 1.19% 10/29/2015 1.37% 02/22/2016 1.11% Various 1.05% 02/12/2016 1.06% 10/11/2016 1.13% 07/06/2017 1.59% Various 1.78% 11/01/2017 1.76% Various 2.14% 07/25/201.7 1.78% 02/02/2018 2.46% 10/19/2017 1.88% 08/15/2017 1.77% 12/15/2017 2.11% Various 2.04% 12/26/2017 2.20% Various 2.79% 1,704,925.70 1,721,099.85 1,724,576.18 1,743,286.20 550,345.59 550,104.39 1,912,256.37 1,904,686.36 1,214,957.14 1,204,921.45 1,199,769.65 1,199,905.96 1,341,532.42 1,343,081.49 2,488,516.33 2,506,257.84 2,966,484.38 2,977,615.37 3,863,681.70 3,896,143.30 973,909.60 981,820.44 1,967,265.63 1,973,721.31 1,740,771.48 1,743,087.83 1, 779, 545.09 1,785,095.16 1,783,125.00 1,786,690.61 2,979,453.13 2,983,862.24 2,960,156.25 2,968,053.21 3,364,140.63 3,374,466.58 98.72 2.60% 98.16 2.73% 98.13 2.76% 98.12 2.79% 98.13 2.81% 97.66 2.82% 97.87 2.85% 97.23 2.87% 97.08 2.89% 95.44 2.91% 94.98 2.93% 97.32 2.94% 96.51 2.94% 95.52 2.96% 96.69 2.95% 96.60 2.95% 96.50 2.96% 95.81 2.96% 1,702,966.58 3,814.45 1,717,871.75 7,363.39 539,730.40 2,084.92 1,864,300.90 6,002.03 1,177,593.60 2,825.97 1,171,969.20 1,186.81 1,316,366.30 7,662.09 2,455,070.13 3,052.20 2,912,460.00 113.95 3,817,656.00 15,163.05 949,805.00 989.01 1,946,328.00 110.50 1,688,886.50 12,885.93 1,719,280.80 6,823.37 1,740,375.00 8,529.21 2,898,048.00 9,633.98 2,895,000.00 4,945.05 3,353,437.50 20,638.59 0.87% (18,133.27) 0.88% (25,414.45) 0.28% (10,373.99) 0.96% (40,385.46) 0.60% (27,327.85) 0.60% (27,936.76) 0.68% (26,715.19) 1.26% (51,187.71) 1.49% (65,155.37) 1.96% (78,487.30) 0.49% (32,015.44) 0.99% (27,393.31) 0.87% (54,201.33) 0.88% (65,814.36) 0.89% (46,315.61) 1.49% (85,814.24) 1.48% (73,053.21) 1.72% (21,029.08) Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA Aaa / AA+ AAA 0.75 0.74 1.08 1.06 1.17 1.14 1.25 1.22 1.33 1.30 1.42 1.39 1.62 1.58 1.92 1.87 2.00 1.95 2.67 2.59 2.92 2.83 3.00 2.88 3.08 2.95 3.25 3.12 3.25 3.11 3.33 3.19 3.42 3.27 3.67 3.49 *Please see the disclosures on front page of this presentation. CM i Holdings Report Sample Client As of September 30, 2018 CUSIP Security Description Par Value/Units Purchase Date Book Yield Cost Value Book Value Mkt Price MktYTM Market Value Accrued Int. % of Port. Moody/S&P Gain/Loss Fitch Maturity Duration Sample CUSIP US Treasury Note 1.875% Due 08/31/2022 2,800,000.00 09/18/2018 2.92% 2,691,828.13 2,694,980.95 96.04 2.98% 2,689,094.80 R,991 71 1.38% Aaa / AA+ (5,886.15) AAA 3.84 3.65 TOTAL US Treasury TOTAL PORTFOLIO 43,145,000.00 1.89% 42, 504,970.21 42,638,197.75 2.86% 41,832,884.56 21.44% Aaa / AA+ 130,448.68 (805,313.19) Aaa 2.42 2.33 198,239,183.53 197,349,640.18 1.92% 197,429, 509.42 2.90% 194,859,558.89 100.00% 868,070.93 (2,569,950.53) Aa1/AA Aaa 1.87 1.69 TOTAL MARKET VALUE PLUS ACCRUALS 195,727,629.82 *Please see the disclosures on front page of this presentation. Si::::,, Section 4 I Transactions CA Transaction Ledger Sample Client Consolidated June 30, 2018 through September 30, 2018 As of September 30, 2018 Transaction Type Settlement Date CUSIP Quantity Security Description Acq/Disp Price Yield Amount Interest Total Amount Gain/Loss Pur/Sold ACQUISITIONS Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase Purchase 08/03/2018 Sample CUSIP 08/09/2018 Sample CUSIP 08/28/2018 Sample CUSIP 08/28/2018 Sample CUSIP 09/05/2018 Sample CUSIP 09/10/2018 Sample CUSIP 09/11/2018 Sample CUSIP 09/11/2018 Sample CUSIP 09/20/2018 Sample CUSIP 09/21/2018 Sample CUSIP 09/21/2018 Sample CUSIP 09/26/2018 Sample CUSIP 09/30/2018 Sample CUSIP 09/30/2018 Sample CUSIP 3, 000, 000.00 2,105,000.00 1,750,000.00 670,000.00 2,500,000.00 2,000,000.00 1,500,000.00 1,000,000.00 2,800,000.00 2,250,000.00 750,000.00 3,750,000.00 1,600,000.00 500,000.00 Sample Issuer 2.25% Due: 11/05/2018 Sample Issuer 3.15% Due: 08/09/2021 Sample Issuer 2.5% Due: 12/09/2022 Sample Issuer 2.95% Due: 08/22/2022 Sample Issuer 2.46% Due: 02/28/2019 Sample Issuer 1.75% Due: 06/30/2022 Sample Issuer 2.4% Due: 06/07/2021 Sample Issuer 2.7% Due: 01/11/2023 Sample Issuer 1.875% Due: 08/31/2022 Sample Issuer 2.62% Due: 05/20/2019 Sample Issuer 2.38% Due: 01/22/2019 Sample Issuer 3.125% Due: 09/09/2022 Sample Issuer 2.375% Due: 01/19/2023 Sample Issuer 3.375% Due: 12/10/2021 *Please see the disclosures on front page of this presentation. 100.000 2.25% 99.969 3.16% 98.800 2.80% 99.986 2.98% 100.009 2.44% 96.219 2.80% 97.821 3.24% 97.471 3.33% 96.137 2.92% 98.246 2.69% 99.187 2.43% 100.420 3.01% 97.125 3.10% 99.952 3.39% 3, 000, 000.00 2,104, 347.45 1,729,000.00 669,908.08 2,500,227.47 1,924,375.00 1,467,315.00 974,710.00 2,691,828.13 2,210,536.25 743,901.25 3,765,750.00 1, 554, 000.00 499,760.00 187.50 0.00 9,600.69 0.00 1,195.83 6,847.83 9,400.00 4,500.00 2,900.55 0.00 0.00 5,533.85 8,022.22 0.00 3,000,187.50 2,104, 347.45 1,738,600.69 669,908.08 2,501,423.30 1,931,222.83 1,476,715.00 979, 210.00 2,694,728.68 2,210,536.25 743,901.25 3,771,283.85 1,562,022.22 499,760.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Transaction Ledger Sample Client - Consolidated June 30, 2018 through September 30, 2018 As of September 30, 2018 Transaction Type Settlement Date CUSIP Quantity Security Description Acq/Disp Price Yield Amount Interest Total Amount Gain/Loss Pur/Sold Purchase 09/28/2018 Sample CUSIP 650,000.00 Sample Issuer 3% Due: 10/12/2021 99.853 3.05% 649,044.50 595.83 649,640.33 0.00 Subtotal 26,825,000.00 26,484,703.13 48,784.30 26,533,487.43 0.00 TOTAL ACQUISITIONS 26,825,000.00 26,484,703.13 48,784.30 26,533,487.43 0.00 DISPOSITIONS Sale Sale Sale Sale Sale Sale Sale Sale Sale 08/08/2018 Sample CUSIP 08/22/2018 Sample CUSIP 08/28/2018 Sample CUSIP 09/10/2018 Sample CUSIP 09/11/2018 Sample CUSIP 09/11/2018 Sample CUSIP 09/20/2018 Sample CUSIP 09/26/2018 Sample CUSIP 09/26/2018 Sample CUSIP 2,100,000.00 425,000.00 1,000,000.00 1,700,000.00 1,635,000.00 1, 000, 000.00 2, 000, 000.00 2,000,000.00 1, 765, 000.00 Sample Issuer 1.1% Due: 12/05/2018 Sample Issuer 2.125% Due: 10/10/2018 Sample Issuer 1.875% Due: 11/05/2018 Sample Issuer 1.25% Due: 01/31/2019 Sample Issuer 2.35% Due: 01/28/2019 Sample Issuer 1.7% Due: 01/09/2019 Sample Issuer 2.65% Due: 04/01/2019 Sample Issuer 1.25% Due: 01/16/2019 Sample Issuer 1.125% Due: 12/14/2018 99.651 2.18% 99.960 2.41% 99.905 2.37% 99.605 2.27% 99.965 2.44% 99.773 2.39% 100.039 2.57% 99.673 2.32% 99.756 2.25% Subtotal 13, 625,000.00 2,092,671.00 424,830.00 999,050.00 1,693,292.97 1,634,427.75 997,730.00 2,000,780.00 1,993,460.00 1,760,693.40 13,596,935.12 4,042.50 3,311.46 5,885.42 2,367.53 4,589.35 2,927.78 24,880.56 4,861.11 5,625.94 2,096,713.50 428,141.46 1,004,935.42 1,695,660.50 1,639,017.10 1,000,657.78 2,025,660.56 1,998,321.11 1,766,319.34 - 6,518.88 -273.64 -944.33 -7,225.33 - 3,711.27 - 2,515.27 -980.54 -6,528.35 -4,123.88 58,491.65 13,655,426.77 -32,821.49 Maturity 08/01/2018 Sample CUSIP 500,000.00 Sample Issuer 2.1% Due: 08/01/2018 *Please see the disclosures on front page of this presentation. 100.000 500,000.00 0.00 500,000.00 0.00 CM Transaction Ledger Sample Client - Consolidated June 30, 2018 through September 30, 2018 As of September 30, 2018 Transaction Settlement Type Date CUSIP Quantity Security Description Price Acq/Disp Yield Amount Interest Total Amount Gain/Loss Pur/Sold Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity Maturity 08/07/2018 Sample CUSIP 08/10/2018 Sample CUSIP 08/13/2018 Sample CUSIP 08/15/2018 Sample CUSIP 08/15/2018 Sample CUSIP 08/24/2018 Sample CUSIP 09/04/2018 Sample CUSIP 09/04/2018 Sample CUSIP 09/21/2018 Sample CUSIP 09/21/2018 Sample CUSIP 09/25/2018 Sample CUSIP 09/25/2018 Sample CUSIP 09/25/2018 Sample CUSIP 09/27/2018 Sample CUSIP 09/27/2018 Sample CUSIP 09/27/2018 Sample CUSIP 1,350,000.00 3,000,000.00 2,100, 000.00 500,000.00 400, 000.00 2,750,000.00 2, 000, 000.00 500, 000.00 2, 000, 000.00 1, 000, 000.00 1,970,000.00 1, 000, 000.00 2,100, 000.00 1, 500, 000.00 1,000,000.00 2, 700, 000.00 Sample Issuer 0.625% Duc: 08/07/2018 Sample Issuer 1.87% Due: 08/10/2018 Sample Issuer 2.01% Due: 08/13/2018 Sample Issuer 1.15% Due: 08/15/2018 Sample Issuer 1% Due: 08/15/2018 Sample Issuer 1.6% Due: 08/24/2018 Sample Issuer 1.75% Due: 09/04/2018 Sample Issuer 2.34% Due: 09/04/2018 Sample Issuer 1.45% Due: 09/21/2018 Sample Issuer 2.31% Due: 09/21/2018 Sample Issuer 1% Due: 10/05/2018 Sample Issuer 2.32% Due: 10/05/2018 Sample Issuer 2.37% Due: 10/09/2018 Sample Issuer 2.25% Due: 10/10/2018 Sample Issuer 2.23% Due: 10/16/2018 Sample Issuer 1.71% Due: 10/19/2018 100.000 98.940 98.989 100.000 100.000 100.000 100.000 99.194 100.000 99.211 100.000 99.265 98.808 99.444 99.443 100.000 *Please see the disclosures on front page of this presentation. 1,350,000.00 2,968,210.00 2,078,777.75 500,000.00 400, 000.00 2,750,000.00 2, 000, 000.00 495,970.00 2, 000, 000.00 992,107.50 1,970,000.00 992,653.33 2,074,976.75 1,491,656.25 994,425.00 2,700,000.00 0.00 31,790.00 21,222.25 0.00 0.00 48,400.00 0.00 4,030.00 0.00 7,892.50 0.00 7,346.67 25,023.25 8,343.75 5,575.00 46,683.00 1,350,000.00 3,000,000.00 2,100,000.00 500,000.00 400,000.00 2,798,400.00 2, 000, 000.00 500,000.00 2,000,000.00 1,000,000.00 1,970,000.00 1,000,000.00 2,100,000.00 1,500,000.00 1,000,000.00 2,746,683.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 i Transaction Ledger Sample Client - Consolidated June 30, 2018 through September 30, 2018 As of September 30, 2018 Transaction Settlement Type Date CUSIP Quantity Security Description Acq/Disp Price Yield Amount Interest Total Amount Gain/Loss Pur/Sold Maturity Maturity Subtotal 09/28/2018 Sample CUSIP 09/29/2018 Sample CUSIP 300,000.00 1,500,000.00 28,170,000.00 Sample Issuer 2.17% Due: 10/24/2018 Sample Issuer 2.26% Due: 10/29/2018 99.451 100.000 298,354.42 1, 500, 000.00 28,057,131.00 1,645.58 9,605.00 217,557.00 300,000.00 1, 509, 605.00 28,274,688.00 0.00 0.00 0.00 TOTAL DISPOSITIONS 41,795,000.00 41,654,066.12 276,048.65 41,930,11437 -32,821.49 *Please see the disclosures on front page of this presentation. Ca: i Important Disclosures 2020 Chandler Asset Management, Inc, An Independent Registered Investment Adviser. As of September 30, 2018 Information contained herein is confidential. Prices are provided by IDC, an independent pricing source. In the event IDC does not provide a price or if the price provided is not reflective of fair market value, Chandler will obtain pricing from an alternative approved third party pricing source in accordance with our written valuation policy and procedures. Our valuation procedures are also disclosed in Item 5 of our Form ADV Part 2A. Performance results are presented gross -of -advisory fees and represent the client's Total Return. The deduction of advisory fees lowers performance results. These results include the reinvestment of dividends and other earnings. Past performance may not be indicative of future results. Therefore, clients should not assume that future performance of any specific investment or investment strategy will be profitable or equal to past performance levels. All investment strategies have the potential for profit or loss. Economic factors, market conditions or changes in investment strategies, contributions or withdrawals may materially alter the performance and results of your portfolio. Index returns assume reinvestment of all distributions. Historical performance results for investment indexes generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment management fee, the incurrence of which would have the effect of decreasing historical performance results. It is not possible to invest directly in an index. Source ice Data Indices, LLC ("ICE"), used with permission. 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This report is provided for informational purposes only and should not be construed as a specific investment or legal advice. The information contained herein was obtained from sources believed to be reliable as of the date of publication, but may become outdated or superseded at any time without notice. Any opinions or views expressed are based on current market conditions and are subject to change. This report may contain forecasts and forward -looking statements which are inherently limited and should not be relied upon as indicator of future results. Past performance is not indicative of future results. This report is not intended to constitute an offer, solicitation, recommendation or advice regarding any securities or investment strategy and should not be regarded by recipients as a substitute for the exercise of their own judgment. Fixed income investments are subject to interest, credit and market risk. Interest rate risk: the value of fixed income investments will decline as interest rates rise. Credit risk: the possibility that the borrower may not be able to repay interest and principal. Low rated bonds generally have to pay higher interest rates to attract investors willing to take on greater risk. Market risk: the bond market in general could decline due to economic conditions, especially during periods of rising interest rates. Ratings information have been provided by Moody's, S&P and Fitch through data feeds we believe to be reliable as of the date of this statement, however we cannot guarantee its accuracy. Security level ratings for U.S. Agency issued mortgage -backed securities ("MBS") reflect the issuer rating because the securities themselves are not rated. The issuing U.S. Agency guarantees the full and timely payment of both principal and interest and carries a AA+/Aaa/AAA by S&P, Moody's and Fitch respectively. S&P/Case Shiller U.S. National Home Price Index tracks the value of single-family housing within the United States. The S&P Case Shiller 20 City Composite Home Price Index is a value -weighted average of the 20 metro area indices. These metro areas include: Boston, Chicago, Denver, Las Vegas, Los Angeles, Miami, New York City, San Diego, San Francisco, Washington, DC, Atlanta, Charlotte, Cleveland, Dallas, Detroit, Minneapolis, Phoenix, Portland, Seattle and Tampa. *Please see the disclosures on front page of this presentation. CA Benchmark Disclosures As of September 30, 2018 ICE BAML 1-3 Yr US Treasury Index The ICE BAML 1-3 Year US Treasury Index tracks the performance of US dollar denominated sovereign debt publicly issued by the US government in its domestic market Qualifying securities must have at least one year remaining term to final maturity and less than three years remaining term to final maturity, a fixed coupon schedule and a minimum amount outstanding of $1 billion Qualifying secunties must have at least 18 months to final matunty at the time of issuance (Index G1O2 Please visit www mlmdex ml coin for more information) ICE BAML 1-3 Yr US Corp/Govt Rated AAA -A Index The ICE BAML 1-3 AAA -A Year US Corporate & Government Index tracks the performance of US dollar denominated investment grade debt publicly issued in the US domestic market including US Treasury, US agency, foreign government supranational and corporate securities Qualifying securities must be rated AAA through A3 (based on an average of Moody's, S&P and Fitch) In addition, qualifying securities must have at least one year remaining term to final maturity and less than three years remaining term to final maturity, at least 18 months to final maturity at point of issuance, a fixed coupon schedule and o minimum amount outstanding of $1 btlhon for US Treasuries and $250 million for all other securities (Index GVPB Please visit www mhndex ml coin for more information) *Please see the disclosures on front page of this presentation Sample Client Account #00000 Sample GASB 40 Report As of December 31, 2018 ` Portfolio Characteristics Market Value Avg Modified Duration Avg Maturity 25,924,396 2.34 2.45 Sector Interest Rate Shock Analysis Fair value of portfolio after increase of: 100 bps 200 bps 300 bps -606,063 - 1,212,125 - 1,818,188 Sector Characteristics Segmented Time Distribution U S Treasury Agency U S Corporate Foreign Corporate Money Market Fund Fl TOTAL Market Value 12,136,878 9,018,469 4,352,762 339,545 76,742 25,924,396 Avg Mod. Duration 2.16 2.62 2.27 2.82 0.00 2.34 Avg Maturity 2.24 2.76 2.42 3.02 0.00 2.45 % of Port <1 YR 1-3 YRS 3-5 YRS 46.82% 34.79% 16.79% 1.31% 0.30% 100.00% 2,534,555 1,169,287 1,147,920 0 76,742 4,928,504 5,580,662 4,318,551 1,591,340 0 0 4,021,661 3,530,631 1,613,502 339,545 0 11,490,553 9,505,338 >5 YRS 0 0 0 0 0 0 Concentration of Credit Issuer Name Sample Sample Sample Sample Sample Sample Sample Sample Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Cost 12,255,514 4,195,470 3,236,631 1,670,908 501,170 345,093 325,628 325,497 Market Value 12,136,878 4,169,623 3,195,445 1,653,401 499,297 339,545 328,349 326,062 Avg Mod. Duration 2.16 2.63 2.92 2.04 0.17 2.82 4.06 4.18 Avg Maturity 2.24 2.77 3.09 2.13 0.16 3.02 4.49 4.61 % of Port 46.82% 16.08% 12.33% 6.38% 1.93% 1.31% 1.27% 1.26% Please note: This sample client service report is being provided for illustrative purposes to demonstrate Chandler Asset Management's reporting capabilities. References to specific securities and their characteristics are examples of securities held in the portfolio and are not intended to be, and should not be interpreted as an offer, solicitation or recommendation to purchase or sell any financial instrument, an indication that the purchase of such securities was or will be profitable, or representative of the composition or performance of the portfolio. The information contained in this sample presentation is subject to change and obtained from sources we believe to be reliable, but we do not guarantee its accuracy. Portfolio characteristics are based on a sample portfolio managed by Chandler. There is no guarantee that investment in any of these characteristics will result in characteristics similar to those that appear herein due to economic conditions and other market factors, which will fluctuate. Past performance is not indicative of future success. Fixed income investments are subject to interest, credit and market risk. Chandler Asset Management - CONFIDENTIAL Page 1 Sample Client Sample GASB 40 Report Account #00000 As of December 31, 2018 Concentration of Credit Issuer Name Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Cost 323,219 325,575 323,258 323,096 318,926 324,373 313,060 76,742 Market Value 320,691 320,321 319,453 318,726 315,875 315,727 315,383 76,742 Avg Mod. Duration 1.97 2.08 3.75 2.29 2.30 2.51 3.76 0.00 Avg Maturity 2.06 2.17 4.07 2.38 2.38 2.61 4.04 0.00 % of Port 1.24% 1.24% 1.23% 1.23% 1.22% 1.22% 1.22% 0.30% TOTAL 26,169,765 25,924,396 2.34 2.45 100.00% CUSIP Details CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Issue Name Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Sample Issuer Issue Government MMKT Fund #657 Note Note N ote N ote N ote Note Note N ote N ote Cpn 2.00 1.50 2.13 1.95 1.95 1.63 1.75 1.63 1.75 1.50 Maturity Date Is Next Call Callable Date 12/31/2018 02/28/2019 03/01/2019 03/04/2019 03/15/2019 04/30/2019 05/30/2019 08/31/2019 09/12/2019 11/30/2019 N N N N N N N N N N Market Value 76,742 399,428 499,297 324,362 324,262 797,750 498,415 347,689 670,872 989,688 Duration 0.00 0.16 0.17 0.17 0.20 0.33 0.41 0.65 0.68 0.90 Market Term Ratings Moody/SP/Fitch 0.00 Aaa AAA NR 0.16 Aaa AA+ AAA 0.16 Al AA- NR 0.17 A2 A A 0.20 A2 AA- A 0.33 Aaa AA+ AAA 0.41 Aaa AA+ AAA 0.67 Aaa AM- AAA 0.70 Aaa AA+ AAA 0.92 Aaa AA+ AAA Please note: This sample client service report is being provided for illustrative purposes to demonstrate Chandler Asset Management's reporting capabilities. References to specific securities and their characteristics are examples of securities held in the portfolio and are not intended to be, and should not be interpreted as an offer, solicitation or recommendation to purchase or sell any financial instrument, an indication that the purchase of such securities was or will be profitable, or representative of the composition or performance of the portfolio. The information contained in this sample presentation is subject to change and obtained from sources we believe to be reliable, but we do not guarantee its accuracy. Portfolio characteristics are based on a sample portfolio managed by Chandler. There is no guarantee that investment in any of these characteristics will result in characteristics similar to those that appear herein due to economic conditions and other market factors, which will fluctuate. Post performance is not indicative of future success. Fixed income investments are subject to interest, credit and market risk. Chandler Asset Management - CONFIDENTIAL Page 2 Sample Client Account #00000 wiF Sample GASB 40 Report As of December 31, 2018 _______ CUSIP Details CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Sample CUSIP Issue Name Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Sample Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issuer Issue N ote N ote Note Note Note Callable Note Cont 12/13/2022 N ote Callable Note Cont 12/23/22 Note Note Note Callable Note Cont 5/26/2023 Note Note Note Note Note Cpn 1.75 1.88 1.75 2.00 1.88 2.40 2.38 2.85 2.13 3.25 2.75 3.40 3.45 3.38 2.88 1.63 3.38 Maturity Date Is Callable Next Call Date 06/30/2022 08/31/2022 09/30/2022 10/05/2022 10/31/2022 01/13/2023 01/19/2023 01/23/2023 03/10/2023 06/09/2023 06/19/2023 06/26/2023 08/11/2023 09/08/2023 09/12/2023 10/31/2023 12/08/2023 N N N N N Y 12/13/2022 N Y 12/23/2022 N N N Y 05/26/2023 N N N N N Market Value 487,891 587,156 3.49 1,022,274 3.58 490,548 3.58 366,621 3.66 315,383 3.76 719,574 3.79 319,453 244,877 307,603 301,753 328,349 326,062 412,006 384,474 479,903 128,819 Market Duration Term Ratings Moody/SP/Fitch 3.37 3.50 Aaa AA+ AAA 3.67 Aaa 3.75 Aaa 3.76 Aaa 3.84 Aaa 4.04 Aa 1 4.05 Aaa 3.75 4.07 Al 3.95 4.19 Aaa 4.11 4.44 Aaa 4.18 4.47 Aaa 4.06 4.49 Aa2 4.18 4.61 Al 4.28 4.69 Aaa 4.34 4.70 Aaa 4.59 4.84 Aaa 4.52 4.94 Aaa AA+ AAA AA+ AAA AA+ AAA AM- AAA AA+ NR AA+ AAA AA- AA - AA+ AAA AA+ NR AA+ AAA AA AA A AA - AA+ NR AA+ AAA AA+ AAA AA+ AAA TOTAL 25,924,396 Please note: This sample client service report is being provided for illustrative purposes to demonstrate Chandler Asset Management's reporting capabilities. References to specific securities and their characteristics are examples of securities held in the portfolio and are not intended to be, and should not be interpreted as an offer, solicitation or recommendation to purchase or sell any financial instrument, an indication that the purchase of such securities was or will be profitable, or representative of the composition or performance of the portfolio. The information contained in this sample presentation is subject to change and obtained from sources we believe to be reliable, but we do not guarantee its accuracy. Portfolio characteristics are based on a sample portfolio managed by Chandler. There is no guarantee that investment in any of these characteristics will result in characteristics similar to those that appear herein due to economic conditions and other market factors, which will fluctuate. Past performance is not indicative of future success. Fixed income investments are subject to interest, credit and market risk. Chandler Asset Management - CONFIDENTIAL Page 3 Sample Client Account #00000 Sample GASB 72 - Fair Value Measurements As of December 31, 2018 Cat Asset Fair Value Investments That Are Not Measured at Fair Value Quoted Prices in Active Markets for Identical Assets (Level 1) Significant Other Observable Inputs (Level 2) Significant Unobservable Inputs (Level 3) Agency Foreign Corporate Money Market Fund H US Corporate US Treasury TOTAL PORTFOLIO $9,018,469.17 $339,544.80 $76,742.02 $4,352,761.72 $12,136,877.85 $25,924,395.56 $0.00 $0.00 $76,742.02 $0.00 $0.00 $76,742.02 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $9,018,469.17 $339,544.80 $0.00 $4,352,761.72 $12,136,877.85 $25,847,653.54 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 Please note: This sample client service report is being provided for illustrative purposes to demonstrate Chandler Asset Management's reporting capabilities. References to specific securities and their characteristics are examples of securities held in the portfolio and ore not intended to be, and should not be interpreted as an offer, solicitation or recommendation to purchase or sell any financial instrument, an indication that the purchase of such securities was or will be profitable, or representative of the composition or performance of the portfolio. Portfolio characteristics and asset allocation are based on a sample portfolio managed by Chandler. There is no guarantee that investment in any of these characteristics will result in characteristics similar to those that appear herein due to economic conditions and other market factors, which will fluctuate. The information contained in this sample presentation is subject to change and obtained from sources we believe to be reliable, but we do not guarantee its accuracy. Past performance is not indicative of future success. Fixed income investments are subject to interest, credit and market risk. Chandler Asset Management - CONFIDENTIAL Page 1 CAI Appendix H Organizational Chart HUMAN RESOURCE cAtcH4DER ASSET MANAGEMENT I ADMINISTRATION Adriana Haefner* HR Director Trang Nguyen Office Manager ORGANIZATIONAL CHART- PROFESSIONAL STAFF OF 42 COMPLIANCE Joseph Kolinsky* Chief Compliance Officer Jacob Vu Admin Assistant I I OPERATIONS Kristin Franco Director of Investment Ops Mike Ramos Business Analyst Investment Tech Rhea Gutierrez Ross Foster Senior Compliance Sr Investment Officer Operations Specialist Sarah Larsen Garrett Richardson Compliance Sr Investment Associate Operations Specialist Organizational Chart 9/2022 * Denotes member of the Executive Management Committee Ben Gottlieb Operations Specialist Jose Machado - Aguilar Operations Specialist An Phan perations Specialist INVESTMENT MGM William Dennehy* Co CIO I Jayson Schmitt* Co CIO Ted Piorkowski ►-- Senior Portfolio Manager Genny Lynkiewicz Senior Portfolio Manager Scott Prickett* Co CIO Daniel Delaney Senior Portfolio Manager Stephen Church ma Assistant Portfolio Manager Charlotte Powell Aaron Nail — Associate Portfolio Assistant Portfolio Manager Manager Julie Hughes Senior Portfolio Strategist Carlos Oblites Senior Portfolio Strategist Alayne Sampson Senior Portfolio Strategist Karl Meng Portfolio Strategist Kara Raynor -Sanchez — Associate Portfolio Strategist I I BUSINESS DEVELOPMENT 1 Ryan Tauber* Managing Dir of Bus Development BOARD OF DIRECTORS Kay Chandler Marty Cassell Nicole Dragoo Jayson Schmitt Antoinette Chandler Diane Dewbrey RELATIONSHIP MGMT MARKETING Don Penner Dir of National Accounts Mia Corral Brown Senior Relationship Manager Mel Hamilton Senior Relationship Manager Aneii Murthy Senior Relationship Manager Ben Mendenhall Senior Relationship Manager I CLIENT SERVICE Heather Wolfe Content Manager Shumaila Ashraf Marketing Associate David Williams Content Associate Stacey Alderson Client Service Director Desiree Berry Client Service Manager Katie Yuan Client Service Associate Gabrielle Eacock Client Service Associate Appendix I Financial Statements Appendix J Quarterly Returns Report Chandler Quarterly Returns Report Chandler Short Term Strategy YEAR 1O. 2022 gross -3.05% 2Q- -0.93% 3Q 0.03% 4Q -0.65% 2022 net -3.11% -1.00% 2021. gross =0.52% 0.21% 2021 net -0.58% 0.15% -4.00% -0.71% 2020 gross 2.56% 1.30% 0.29% 0.22% 2020 net 2.50% 1.24% 0.23% 0.15% 2019 gross 1.40% 1.71% 0.88% _' 0.49% 2019 net 1.34% 1.64% 0.81% 0.43% 2018 gross -0.39% 0.24% 0.26% 1.42% 2018 net -0.46% 0.18% 0.20% 1.36% 2017 gross 0.47% 0.51% 0.38% -0.28% 2017 net 0.40% 0.45% 0.31% -0.34% 2016 gross .51% 0.73% -0.05% -0.89%. 2016 net 1.44% 0.67% -0.11% -0.95% 2015 gross 0.94% -0.03% 0.66% -0.43% 2015 net 0.88% -0.09% 0.60% -0.49% 2014 gross 0.36% 0.61% -0.06% 0.51% 2014 net 0.30% 0.54% -0.13% 0.44% 2013 gross 0.19% -0.76% 0.54% 0.07% 2013 net 0.13% -0.83% 0.48% 0.01% 2012 gross 0.39% 0.60% 0.64% 0.15% 2012 net -0.11% 0.57% 0.58% 0.09% Quarterly performance shown for the Chandler Short Term Bond composite from 1/1/12 through 6/3022. Performance shown are both gross and net of fees. Please refer to this composite's GIPS Composite Report included within the Appendices of this REP for important disclosures regarding calculation of performance net of fees. Past performance is not a guarantee of future results. Chandler Limited Maturity Strategy 2022 net rgos 2021 net -0.18% -0.02% 0.01% -0.54% -2.26% !020 gros 0. 0. 2020 net 1.87% 0.87% 0.15% 0.09% °l5 0 2019 net 1.09% 1.32% 0.69% 0.47% 21 f 0 2018 net -0.18% 0.26% 0.32% 1.04% ass 0. .33 0' 2017 net 0.27% 0.27% 0.26% -0.20% 6`gro 0.. 2016 net 0.94% 0.45% -0.08% -0.45% gross 0,`61%. 2015 net 0.55% 0.01% 0.32% -0.39% 14 gross ; 3 01% 2014 net 0.18% 0.30% -0.05% 0.19% :11 12% 2013 net 0.10% -0.43% 0.33% 0.06% 0. 2012 net 0.21% 0.24% 0.39% 0.06% Quarterly performance shown for the Chandler Limited Maturity composite from 1/1/12 through 6/3022. Performance shown are both gross and net of fees. Please refer to this composite's GIPS Composite Report included within the Appendices of this RFP for important disclosures regarding calculation of performance net of fees. Past performance is not a guarantee of future results. Chandler Ultra Short Bond Strategy YEAR 1Q 2Q 3Q 4Q 2022 gross -1,07% ' -0.22%'' 2022 net -1.13% 0.28% 2021 gross 0.02% 0.05% 0.04% -0.26% 2021 net -0,05% -0.01% -0.03% -0.32% 2020 gross 0.72% 1.06% 0.15% 0.15% 2020 net 0.65% 0.99% 0.09% 0.09% 2019 gross 0.99% 1.01% 0,67% 0.58% 2019 net 0.92% 0.95% 0.61% 0.52% 2018 gross 0.13% 0.49% 0.59% 0.74% 2018 net 0.07% 0.43% 0.52% 0.68% 2017 gross 0.28% 0.27% 0.32% 0.11% 2017 net 0.22% 0.21% 0.26% 0.05% 2016 gross 0.52% 0.35% 0.08% 0.02%' 2016 net 0.45% 0.29% 0.02% -0.04% 2015 gross 0.25% 0.09% 0.20% -0.08% 2015 net 0.19% 0.03% 0.13% -0.14% 2014 gross 0.14% 0.08% 0.06% 0.08% 2014 net 0.08% 0.12% 0.00% 0.01% 2013 gross 0.12% -0.04% 0.20% 0.11%' 2013 net 0.06% -0.10% 0.14% 0.05% 2012 gross 0.39% 0.13% 0.23% 0.07% 2012 net -0.11% 0.07% 0.16% 0.00% Quarterly performance shown for the Chandler Ultra Short Term Bond composite from 1/1/12 through 6/3022. Performance shown are both gross and net of fees. Please refer to this composite's GIPS Composite Report included within the Appendices of this RFP for important disclosures regarding calculation of performance net of fees. Past performance is not a guarantee of future results. CHANDLER ASSET MANAGEMENT Exhibit C Request for Proposals (B2200146) for Investment Advisor Services WELD COUNTY, COLORADO BEST AND FINAL FEE OFFER On behalf of Chandler Asset Management, Inc. ("Chandler"), we thank the County for the opportunity to provide a Best and Final Offer for your consideration. Please note that we have revised our fee schedule from what we proposed originally. The proposed fee is an all-inclusive basis points fee and is based on the total portfolio of assets under our management. Please note Chandler does not charge fees on funds held in vehicles not directly under our management, including Local Government Investment Pools. Our proposed fee for year one and four one-year renewal options and is intended to address the services as we understand them to be outlined in the Request for Proposal. Proposed Fee Schedule for Weld County Assets Under Management Annual Asset Management Fee Firs` Assets over $150 million 0.03 of 1% (3 basis points) For example, the all-inclusive annual fee on a portfolio of $450 million would be 6 basis points on the first $150 million for a fee of $90,000 plus 3 basis points on the additional $300 million for a fee of $90,000 for a total annual fee in this example of $180,000. Our proposed fee is variable based on the assets under management and this is not a fixed fee for our services. Example fee calculation for a portfolio of $450 Million: Total Assets Under Annual Fee in Basis Management Points Annual Fee in $ dollars $150 million Next $300 million 6.0 bps 3.0 bps $90,000 $90,000 Total $450 million 4.0 bps $180,000 We are dedicated to personalized client service that is equal to our commitment as fiduciaries. If you have any questions, please contact Scott Prickett, Co -Chief Investment Officer, directly at (720) 308-6102 or via email at sprickett@chandlerasset.com. Sincerely, CHANDLER ASSET MANAGEMENT, INC. Nicole Dragoo, JD, IACCP President Exhibit D ADDITIONAL TERMS SPECIFIC TO INVESTMENT MANAGEMENT RELATIONSHIP 1. Client Representative. In its capacity as investment manager, Chandler shall receive all instructions, directions and other communications on Client's behalf respecting Client's account from Cheryl Pattelli (Representative). Chandler is hereby authorized to rely and act upon all such instructions, directions and communications from such Representative or any agent of such Representative. 2. Investment Policy. In investing and reinvesting Client's assets, Chandler shall comply with Client's Investment Policy, which is attached hereto as part of Exhibit A. 3. Authority of Chandler. Chandler is hereby granted full discretion to invest and reinvest all assets under its management in any type of security it deems appropriate, subject to the instructions given or guidelines set by Representative. 4. Notices. All reports and other communications required hereunder to be in writing shall be delivered in person, or sent by first-class mail postage prepaid, by overnight courier, by confirmed facsimile with original to follow or by confirmed electronic mail with proof of receipt to the addresses set forth below. Either party to this Agreement may, by written notice given at any time, designate a different address for the receipt of reports and other communications due hereunder. Chandler Asset Management Attn: Nicole Dragoo 6225 Lusk Boulevard San Diego, CA 92121 Client Representative Attn: Cheryl Pattelli, CFO Weld County 1150 O Street Greeley, CO 60302 5. Electronic Delivery. From time to time, Chandler may be required to deliver certain documents to Client such as account information, notices and required disclosures. Client hereby consents to Chandler's use of electronic means, such as email, to make such delivery. This delivery may include notification of the availability of such document(s) on a website, and Client agrees that such notification will constitute "delivery". Client further agrees to provide Chandler with Client's email address(s) and to keep this information current at all times by promptly notifying Chandler of any change in email address(s). Client email address(s): cpaelli@weldgov.com 6. Proxy Voting. Chandler will vote proxies on behalf of Client unless otherwise instructed. Chandler has adopted and implemented written policies and procedures and will provide Client with a description of the proxy voting procedures upon request. Chandler will provide information regarding how Clients' proxies were voted upon request. To request proxy policies or other information, please contact us by mail at the address provided, by calling 800-317-4747 or by emailing your request to info@chandlerasset.com. 7. Custody of Securities and Funds. Chandler shall not have custody or possession of the funds or securities that Client has placed under its management. Client shall appoint a custodian to take and have possession of its assets. Client recognizes the importance of comparing statements received from the appointed custodian to statements received from Chandler. Client recognizes that the fees expressed above do not include fees Client will incur for custodial services. 8. Valuation. Chandler will value securities held in portfolios managed by Chandler no less than monthly. Securities or investments in the portfolio will be valued in a manner determined in good faith by Chandler to reflect fair market value. 9. Investment Advice. Client recognizes that the opinions, recommendations and actions of Chandler will be based on information deemed by it to be reliable, but not guaranteed to or by it. Provided that Chandler acts in good faith, Client agrees that Chandler will not in any way be liable for any error in judgment or for any act or omission, except as may otherwise be provided for under the Federal Securities laws or other applicable laws. 10. Payment of Commissions. Chandler may place buy and sell orders with or through such brokers or dealers as it may select. It is the policy and practice of Chandler to strive for the best price and execution and for commission and discounts which are competitive in relation to the value of the transaction and which comply with Section 28(e) of the Securities and Exchange Act. Nevertheless, it is understood that Chandler may pay a commission on transactions in excess of the amount another broker or dealer may charge, and that Chandler makes no warranty or representation regarding commissions paid on transactions hereunder. 11. Other Clients. It is further understood that Chandler may be acting in a similar capacity for other institutional and individual clients, and that investments and reinvestments for Client's portfolio may differ from those made or recommended with respect to other accounts and clients even though the investment objectives may be the same or similar. Accordingly, it is agreed that Chandler will have no obligation to purchase or sell for Client's account any securities which it may purchase or sell for other clients. 12. Confidential Relationship. The terms and conditions of this Agreement, and all information and advice furnished by either party to the other shall be treated as confidential and shall not be disclosed to third parties except (i) as required by law, rule, or regulation, (ii) as requested by a regulatory authority, (iii) for disclosures by either party of information that has become public by means other than wrongful conduct by such party or its officers, employees, or other personnel, (iv) for disclosures by either party to its legal counsel, accountants, or other professional advisers, (v) as necessary for Chandler to carry out its responsibilities hereunder, or (vi) as otherwise expressly agreed by the parties. 13. Receipt of Brochure and Privacy Policy. Client hereby acknowledges receipt of the disclosure statement or "brochure" and "brochure supplement" also known as Part 2A and Part 2B of Form ADV, required to be delivered pursuant to Rule 204-3 of the Investment Advisers Act of 1940 (Brochure). Client further acknowledges receipt of Chandler's Privacy Policy, as required by Regulation S -P. 2 Contract Form New Contract Request Entity Information ❑ New Entity? Entity Name* Entity ID* CHANDLER ASSET MANAGEMENT, INC X00046396 Contract Name. PROFESSIONAL SERVICE AGREEMENT BETWEEN WELD COUNTY AND CHANDLER ASSET MANAGEMENT, INC. Contract Status CTB REVIEW Contract Description* AGREEMENT FOR INVESTMENT ADVISORY SERVICES Contract Description 2 Contract Type. AGREEMENT Amount. $ 180,000.00 Renewable. YES Automatic Renewal Grant Department FINANCE Department Email CM-Fi nance@weldgov.com Department Head Email CM-Finance- DeptHead@weldgov.com County Attorney GENERAL COUNTY ATTORNEY EMAIL County Attorney Email CM- COU NTYATTORN EY<RWELDG OV,COM Contract ID 6504 Contract Lead. CPATTELLI Contract Lead Email cpattelIi@co.weld.co.us Requested BOCC Agenda Date. 11/28,2022 Parent Contract ID Requires Board Approval YES Department Project I Due Date 11./24,,2022 Will a work session with BOCC be required?* HAD Does Contract require Purchasing Dept. to be included? If this is a renewal enter previous Contract ID If this is part of a MSA enter MSA Contract ID Note: the Previous Contract Number and Master Services Agreement Number should be left blank if those contracts are not in On Rase Contract Date Effective Date 11/28:2022 Review Date. 1 1 :28,/'2022 Renewal Date 11/28/2023 Termination Notice Period Committed Delivery Date Expiration Date Contact Information Contact Info Contact Name Contact Type Contact Email Contact Phone 1 Contact Phone 2 Purchasing Purchasing Approver Purchasing Approved Date Approval Process Department Head Finance Approver Legal Counsel ESTHER GESICK CHRIS D'OVIDIO BRUCE BARKER DH Approved Date Finance Approved Date Legal Counsel Approved Date 11/21/2022 11/21/2022 11/23/2022 Final Approval BOCC Approved Tyler Ref # YES 2022-2954 BOCC Signed Date 11 28 2022 BOCC Agenda Date 11/28 2022 Originator CPATTELLI /II To: From: Subject: Board of County Commissioners Cheryl Pattelli, CFO Investment Advisor Selection Process and Recommendation Staff had a work session on Sept. 20th receiving approval to go out to bid for investment advisor services. The Investment Advisor Service RFP was published on Sept. 21. with a submittal deadline of Oct. 19tH The County received a total of 10 RFP responses that were reviewed by Don Warden and Cheryl Pattelli. The RFP responses can be found here: https://weldcounty.sharefile.com/d- sda4e2ad8b00d4195b2fc37001896f57a. Based on the RFP evaluation (see Attachment A), 4 firms were asked to the next step of a Teams interview. Interviews were held on Nov. 2"d and 3'd and the interview evaluation team included Don Warden, Renee Fielder, and Cheryl Pattelli. Based on the interview evaluation (see Attachment B), 2 firms, Chandler Asset Management, Inc. and PFM Asset Management, LLC, were moved onto the next step which included asking for a "Best and Final Offer" and checking references. Based on the RFP and interview evaluations, reference checks, and cost, staff is recommending moving forward with Chandler Asset Management, Inc. as the county's investment advisor. Chandler was rated the highest in both the RFP and interview evaluations and also has lower fees than PFM (see Attachment C). Fees are calculated on portfolio assets and, based on $450M, Chandler fees would be $180,000/year. Staff will work on contracting with Chandler and bring to the BOCC for final approval in the next few weeks. Staff does want to note that Chandler Assets was ultimately the second lowest cost respondent. The RFP was a quality -based selection and price was only one component of different criteria used to determine the best firm for the County. The lowest cost respondent, Dana Investments, was not chosen due to the following factors: Lack of presence in the Colorado market. The city of Vail is currently Dana Investment's sole Colorado client with only $25.9M in assets under them. Small overall and average municipal portfolio. Dana Investment only has $877M of assets for municipal clients with the average municipal client portfolio at $25M. Weak investment strategy and technology. Dana Investment works typically with clients who lean more towards cash and overly conservative investment strategies. No solid investment recommendations were made for the county when asked. Dana Investment also has a very small brokerage network and no customer investment portal. Poor quality presentation and interview. Dana Investment's presentation and interview were unsatisfactory. Their answers to the evaluation team's questions were oftentimes confusing. ?Da- ZqsLi F100 -1L0 Attachment A Investment Advisor REP Evaluation Item Scope of the proposal and project Quality and responsiveness s present a clear un d approach in completing the ro Tom Corresponding Bid Specifications for Best Value Evaluation Firm copabilities and key s,7,:1 ua8flcations and experience Recent experience in successfully performing similar s� Does the firm ...We= client relationships? D es the project manager and team memhers have the experience required to complete this project? Has the team completed a project of this size and complexity? uoes Total Cost Is the price r Total Grand Total li d understand Weld County needs? Total Possible Points Investment Advisors, Mc PFM Asset Management LLC Welh Fargo Advisors Wells Fargo. Private Bank Chandler Asset Management; Inc Public Trust Advisors,. PNC Capital Advisors, LLC Gar4a Hamilton and Assodates Federated Hermes,.lnc RBCGlobal Asset Management Inc. 15 10 35 10 10 10 30 45 20 100 15 10 10 35 6 4.5 9.5 8.5 36.5 20 20 91.5 15 10 10 35 10 10 30 30 45 17.5 17.5 97.5 32.5 5.5 8 6.5 33 2.5 2.5 29 28 .5 1.5 58.5 15 10 10 35 SO 45 15 10 SO 35 9.5 5 10 SO 18.5 18.5 98.5 19 19 98.5 15 10 10 35 8.5 31.5 3.5 3.5 70 15 35 5 4.5 8.5 32 1.5 1.5 15 10 10 35 8.5 8 31.5 15 10 10 35 39 72.5 2 Attachment B Investment Advisor Final Interview Evaluation Item Investment Advisor Final Interview Evaluation 1 Investment Team Qualifications a. The investment team holds adequate qualifications and a proven track record to complete projects of this scope and complexity Total Possible Points Chandler Asset Management Public Trust Advisors Dana Investment PFM Asset Management 10 10.00 9.33 8.33 9.67 b. The team members demonstrate effective communication skills 20 19.67 17.33 15.33 18.33 Total 30 29.67 26.67 23.67 28.00 2 Presentation a. The team's presentation was clear and easy to understand 15 14.33 12.67 10.67 15.00 c. The team's use of audio-visual aids was effective 5 5.00 4.67 4.33 5.00 d. Members of the team that was proposed specifically for this project were present at the interview 10 10.00 10.00 9.33 10.00 Total 30 29.33 27.33 24.33 30.00 3 Questions/Answers Section a. The team provided good answers to the questions asked by the selection committee 20 19.67 17.00 13.67 19.67 b. The answers provided by the team demonstrate a clear understanding of the project and the goals 20 19.67 18.33 13.67 20.00 Total 40 39.33 35.33 27.33 39.67 Grand Total 100 98.33 89.33 75.33 97.67 3 Attachment C Investment Advisor RFP Fees Fees Danalnvestment Advisors, Inc - PFM Asset Management LSC' Original Proposal Bert and Final Offer Wells Fargo Advisors Wells Fargo Private Bank Chandler Asset Management Inc Original Proposal Bert and Final Offer Public Trust Advisors, tit PNC Capital Advisors, LI.C Garcia Hamilton and. Associates. Federated Hermes, Inc RBC.Global Asset Management Inc $0-$200M =.03% .045% of all assets .0425% of all assets .08% of all assets .10% of all assets $0-$150M =.06% $0-$150M =.06% .04% on all assets $0-$100M =.30% $0-$25M =.14% $0-$500M = .06% $0-$100M =.08% $201M -$450M=.02% $451M+=,01% $151M -$200M=.05% $200M+ =.03% $150M+=.03% $101M -$300M=.06% $300M+ $26M -$50M =.12% $517-$37-'08% % $3017+= .OB% $501M+=.05% $101-$500M=.06% $501+=.05% Minimum investment required? No minimum listed $25,000 $25,000 No minimum listed No minimum listed No minimum listed No minimum lined No minimum listed $2007 minimum No minimum listed $2007 minimum No minimum listed Fees per investment amount''''. $4007 $100,000 $180,000 $170,000 $320,000 $400,000 $175,000 5165,000 $160,000 $330,000 $395,000 $240,000 $260,000 $450M $5007 $110,000 $115,000 $202,500 $225,000 $341,250 5212,500 $360,000 $400,000 $450,000 $500,000 $190,000 $205,000 $7,60,000 $195,000 $180,000 $200,000 $365,000 $400,000 $435,000 $475,000 $270,000 $300,000 $290,000 $320,000 $5501 $120,000 $247,500 $233,750 $440,000 $550,000 $220,000 $210,000 $220,000 $435,000 $515,000 $325,000 $345;000 WELD COUNTY PURCHASING 1150 O Street, Room #107, Greeley, CO 80631 reverett 5iweldoov.com cgeisert@weldgov.com cmpeters@weldgov.com Phone: 970-400-4222, 4223 or 4216 DATE OF BID: OCTOBER 19, 2022 REQUEST FOR: INVESTMENT ADVISOR SERVICES DEPARTMENT: FINANCE BID NO: B2200146 PRESENT DATE: OCTOBER 24, 2022 APPROVAL DATE: TBD VENDORS DANA INVESTMENT ADVISORS, INC PO BOX 1067 BROOKFIELD, WI 53008-1067 PFM ASSET MANAGEMENT LLC 950 17TH ST DENVER, CO 80202 WELLS FARGO ADVISORS 10877 WILSHIRE BLVD, 17TH FLOOR LOS ANGELES, CA 90024 WELLS FARGO PRIVATE BANK 1700 LINCOLN AVE DENVER, CO 80274 CHANDLER ASSET MANAGEMENT, INC 6225 LUSK BLVD SAN DIEGO, CA 92121 PUBLIC TRUST ADVISORS 717 17TH ST, STE 1850 DENVER, CO 80202 PNC CAPITAL ADVISORS, LLC 1144 15TH ST, STE 3650 DENVER, CO 80202 GARCIA HAMILTON AND ASSOCIATES 1401 MCKINNEY ST, STE 1600 HOUSTAN, TX 77010 FEDERATED HERMES, INC 1001 LIBERTY AVE PITTSBURGH, PA 15222 RBC GLOBAL ASSET MANAGEMENT (U.S.) INC 50 SOUTH SIXTH ST, STE 2350 MINNEAPOLIS, MN 55402 LATE PROPOSAL - WILL NOT BE CONSIDERED ZEPHYR GROUP AT MORGAN STANLEY 3033 E 1ST AVE, STE 820 DENVER, CO 80206 THE FINANCE DEPARTMENT IS REVIEWING THE PROPOSALS. 2022-2954 FIOO C0 Hello