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SPTC: How We Safeguard Your Assets

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Our internal controls and policies are for the safety and soundness of your assets. SEI Private Trust Company does not commingle your assets with its own or other investors. All brokers and banks can commingle investor funds. They can lend securities, offer margin lending and use their clients' assets as collateral for their own borrowing. Unfortunately, this commingling of funds has been a factor in many fraud situations. As a federal savings association, SEI Private Trust Company does not commingle funds or use client funds in its own account for any use —lending or otherwise —because all client assets are held in an account under the client's name. SEI Private Trust Company does not participate in margin lending. Margin lending, in which client assets are used as collateral for the broker's or bank's lending activities, has also been seen as a primary cause of at least one high- profile failure. SEI Private Trust Company cannot pledge, lend or margin client assets that are held in its custody. SEI Private Trust Company —not an outside firm — maintains custody of all client assets. Perhaps one of the largest frauds in financial history was perpetrated through manipulation of custody records for client accounts. SEI does not allow custody of client assets by any of the investment firms with which we work. Instead, all assets are held at SEI Private Trust Company. While our third-party money managers are responsible for security selection, we do not send client funds to these firms. We do not purchase products from these firms. They are simply granted access to trade securities on our platform, which we then monitor. And even though we do not allow outside firms to custody our clients' assets, we still perform rigorous due diligence on them. Other safeguards and services provided to help with your protection Insurance To help protect investors from employee errors and omissions events, SEI maintains a current Errors and Omissions Professional Liability policy. In addition, SEI provides fidelity bond coverage for protection against employee dishonesty, including forgery or alteration, premises, transit, counterfeit currency, computer systems and other coverages. Services As the custodian of your financial assets, SEI Private Trust Company is responsible for the following services: • Safekeeping: Storage of your financial assets • Reporting package: Periodic statement reporting that details your account value and activity, quarterly performance reports, and year-end tax reporting to assist you in completing your income tax forms • Trade settlement: Receipt and delivery of securities and collection and distribution of proceeds from purchases and sales • Income distribution: Collection and payment of dividends and interest payments • Custodian-to-custodian transfers: Accounting for the movement of securities from and to other custodians • Cash processing: Collection of assets and distribution of withdrawals • Corporate action accounting: Accounting for activities such as stock splits and mergers 3

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