PRIVACY NOTICE

Spectrum Financial, Inc. honors our client’s right to privacy and strives to maintain the highest standards of confidentiality. In that respect, we are providing this Privacy Notice to all of our clients in accordance with Regulation S-P as released by the SEC (Securities Exchange Commission).

Privacy Policy: Spectrum’s policy is to protect personal client information. We do not sell or maintain lists for any outside nonaffiliated marketing firms. We are committed to maintaining physical, electronic, and procedural safeguards to protect any personal information we obtain about our clients.

Information Collected About You. The non-public personal information we collect about our clients comes primarily from the account applications, management agreements, and client profiles you submit to us when opening a managed account. We may also collect information about your transactions and account history for your managed accounts through various nonaffiliated companies such as mutual funds, life insurance companies, brokerage houses and trust companies.

Use and Disclosure of Information: Spectrum will not disclose personal client information, except as permitted by law under the following circumstances:

Your written request to provide information to a third party. To establish or maintain an account with a nonaffiliated third party, such as a clearing broker, life insurance company, trust company or mutual fund company in which Spectrum would actively manage. To sub-advisers contracted by Spectrum to actively manage specific strategies. To render services that you have requested (as in completing a wire transfer or other withdrawal from your account) or any other services provided to you on our behalf. To government entities or other third parties in response to subpoenas or other legal processes as required by law.

Security Policy: We maintain physical, electronic, and procedural security measures that comply with applicable state and federal regulations to safeguard confidential client information. Access to confidential client information is authorized only for those Spectrum employees who require information to perform their job functions.

Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.

Changes to this Privacy Notice: If we make any substantial changes in the way we use or disseminate confidential information, we will notify you.

Spectrum does not provide services for proxy voting to its clients. All proxies are sent directly to clients from the custodian. Spectrum periodically reviews client options at each custodian to ensure proper coding is maintained on all client accounts. If any client receives material contrary to Spectrum’s proxy voting statement, they should contact our office immediately. Spectrum occasionally votes proxies for its principals. Questions concerning proxy voting can be directed to our Client Services Department.

Spectrum offers the Firm Brochure ADV Part 2 and Part 3 (CRS) on the opening of each client account and material changes as they apply. To ensure all clients are offered our updated Firm Brochure ADV Part 2 and Part 3 (CRS) you can request a copy by calling our office at 757-463-7600 or download from our disclosures on our website www.InvestSpectrum.com.

Spectrum offers its Code of Ethics on the opening of each client account. To ensure all clients are offered our Code of Ethics, you can request a copy by calling our office at 757-463-7600 or download from our disclosures on our website www.InvestSpectrum.com.

It is important to contact Spectrum if there are any changes in your personal/financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services to you. Please also advise Spectrum if you intend for us to impose, add, or modify any restrictions to our management services for your account.

Spectrum Financial's website is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links. Accordingly, the publication of Spectrum Financial’s website on the Internet should not be construed by any consumer and/or prospective client as Spectrum Financial’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by Spectrum Financial with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides.

For information pertaining to the registration status of Spectrum Financial, please contact the SEC or the state securities law administrators for those states in which Spectrum Financial maintains a notice filing. A copy of Spectrum Financial’s current written disclosure statement discussing Spectrum Financial’s business operations, services, and fees is available from Spectrum Financial upon written request.

Spectrum Financial does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Spectrum Financial’s web site or incorporated herein, and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Past performance may not be indicative of future results. Therefore, no current or prospective client should assume that future performance of any specific investment, investment strategy (including the investments and/or investment strategies recommended or undertaken by Spectrum Financial) or product made reference to directly or indirectly by Spectrum Financial in its website, or indirectly via a link to an unaffiliated third party website, will be profitable or equal the corresponding indicated performance level(s).

Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client or prospective client’s investment portfolio. Historical performance results for investment indices and/or categories generally do not reflect the deduction of transaction and/or custodial charges, the deduction of an investment management fee, nor the impact of taxes, the incurrence of which would have the effect of decreasing historical performance results.

Certain portions of Spectrum Financial’s web site (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, Spectrum Financial’s (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from Spectrum Financial, or from any other investment professional. Spectrum Financial staff members are neither attorneys nor accountants, and no portion of the website content should be interpreted as legal, accounting or tax advice.

To the extent that any client or prospective client utilizes any economic calculator or similar device contained within or linked to Spectrum Financial’s web site, the client and/or prospective client acknowledges and understands that the information resulting from the use of any such calculator/device, is not, and should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice from Spectrum Financial, or from any other investment professional.

Spectrum Financial’s asset management programs generally involve above-average portfolio turnover, which could negatively impact upon the net after-tax gain experienced in taxable accounts.

CODE OF ETHICS: Available as .pdf

SOCIAL MEDIA DISCLOSURE: Available as .pdf