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Combined Disclosure Document
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In order to provide the investment products and services you have requested, we disclose Personal Information about you to financial institutions ("Third Party Financial Service Providers"), such as our clearing broker, Pershing LLC as required to meet our obligations to you or as permitted by law.

ALIGHT FINANCIAL SOLUTIONS LLC
PRIVACY STATEMENT
WE RESPECT PRIVACY
 

We at AFS appreciate that you have provided us with your personal financial information. We strive to maintain the privacy of such information. This Privacy Statement describes what non-public personal information we collect about you, why we collect it, and when we may share it with others. The Privacy Statement is available for viewing on AFS' website at AlightFinancialSolutions.alight.com and is subject to revision as required from time to time.

 
PERSONAL INFORMATION COLLECTED BY AFS
 

Throughout this Privacy Statement, we refer to the non-public information that personally identifies you as "personal information." To serve its customers better, AFS must collect and maintain accurate non-public information that personally identifies its customers ("Personal Information"). We obtain this information from applications and other forms submitted to us, from your relationship with us, from consumer reporting agencies, from our Web sites, and from third parties and other sources. For example:

    We MAY collect the following kinds of Personal Information through applications and other forms submitted to us, such as:

    • Identifier and contact information such as your name, date of birth, address, e-mail address, telephone/fax numbers, Social Security Number, mother's maiden name;
    • Information about Participant beneficiaries, including, for example, name, Social Security Number, date of birth, address, and telephone numbers;
    • Financial information such as net worth, and tax bracket; and
    • Banking information such as the name of a bank, its contact information and routing number, the type of account held, and the identification number of those accounts.
 

We collect Personal Information about transactions conducted through AFS, such as account balances, account activity, and investment history. We collect information about the use of products and services offered by our affiliates, including Alight Solutions LLC (collectively, "Alight Solutions"). We may obtain Personal Information about customer creditworthiness and credit history from consumer reporting agencies. We may collect Personal Information from other sources in connection with providing or servicing your account.

 

Through our Web sites, we may collect Personal Information that is provided directly through online communications (such as an e-mail address). We may also collect Personal Information about customers Internet service provider, domain names, computer's operating systems and Web browsers, customers' use of our Web sites and customer product and service preferences, through the use of cookies, as defined above. AFS may use cookies for some administrative purposes, for example, to store its customers' preferences for certain kinds of information. None will contain information that will enable anyone to contact its customers via telephone, e-mail, or any other means. If you are uncomfortable with the use of cookie technology, browsers can be set to refuse cookies. Certain of AFS' services, however, may be dependent upon the use of cookie technology and the disabling of cookies could impede the operation of such services.

 
PERSONAL INFORMATION DISCLOSED BY AFS
 

To provide you with the products and services requested, to serve you better, and to manage our business we may disclose Personal Information as required or permitted by law, as described below.

 

Third Party Financial Service Providers: In order to provide the investment products and services you have requested, we may disclose Personal Information to financial institutions ("Third Party Financial Service Providers"), such as our Clearing Agent as is necessary to meet our obligations to you or as permitted or required by law.

 

PLEASE NOTE: When you sign up for a financial product or service offered through AFS, the Third Party Financial Service Provider may acquire Personal Information about Participants, including from AFS, from you, and from third parties. The Third-Party Financial Service Provider's use of such Personal Information, including the Personal Information disclosed by AFS, is governed by a separate privacy policy. AFS urges you to review these privacy policies carefully and to exercise any choices you may have about how Third Party Financial Service Providers use and disclose your Personal Information. Again, please refer to the AFS Privacy Statement that may be found at AlightFinancialSolutions.alight.com.

 

Alight Affiliates: In order to manage your account effectively, including servicing and processing transactions, to inform about products and services offered by us, our affiliates, and others, and as otherwise required or permitted by law, we may disclose Personal Information to Alight Affiliates. Such disclosures also may be required under separate agreements you may have with other Alight Affiliates and may be accordingly addressed under a separate privacy policy(ies).

 

Other Third Parties: Except as described above, we do not disclose Personal Information to non-affiliated third parties except to enable them to provide the products or services you have requested, to provide various other services on our behalf, or as is otherwise required or permitted by law. For example, some instances where we may disclose Personal Information to third parties include: servicing and processing transactions, protecting against fraud, maintaining institutional risk control, responding to judicial process or performing services on our behalf. When we share Personal Information with these companies, they are required to limit their use of that information to the particular purpose for which it was shared and they are not allowed to share it with others except to fulfill that limited purpose.

 

We respect privacy and do not share Personal Information with third parties for marketing purposes.

 
PROTECTING PERSONAL INFORMATION
 

We maintain physical, electronic and procedural security measures to help safeguard the Personal Information we collect. We have internal policies governing the proper handling of Personal Information. We require third parties that provide support or marketing services on our behalf to adhere to confidentiality standards with respect to such information.

 

Important information for Vermont residents.

 

If you are a resident of Vermont, and for as long as you remain a resident of Vermont, the information we may share about you with other financial institutions with which we have a joint marketing agreement is limited to your name, contact information, and information about our transactions and experiences with you. Additionally, within the Alight family we will not share certain information (other than information about our transactions and experiences with you) from account applications or information we receive from third parties without your authorization. To authorize the sharing of this information within the Alight family, please contact us directly.

 
CONTACT INFORMATION
 

If you have any questions or complaints about AFS' use of Personal Information or about this Alight Financial Solutions Privacy Statement, please send an email to: dataprivacy@alight.com .

 

AFS reserves the right to amend this Alight Financial Solutions Privacy Statement at any time. We will inform you of any changes to this Privacy Statement as required by law.

 

Effective: April 1, 2007

 
AFS RESERVES THE RIGHT TO AMEND THIS ALIGHT FINANCIAL SOLUTIONS PRIVACY
STATEMENT AT ANY TIME. WE WILL INFORM YOU OF ANY CHANGES TO THIS
PRIVACY STATEMENT AS REQUIRED BY LAW.


Important Information on Penny Stocks

It is important for our customers to understand that trading penny stocks can be very risky. Penny stocks are low-priced shares of small companies not traded on an exchange or quoted on NASDAQ. Prices often are not available. Generally a penny stock is a security that:

  • Is priced under five dollars
  • Is not traded on a national stock exchange or on NASDAQ (the FINRA's automated quotation system for actively traded stocks);
  • May be listed in the "pink sheets" or the FINRA OTC Bulletin Board'
  • Is issued by a company that has less than $5 million in net tangible assets and has been in business less than three years, by a company that has under $2 million in net tangible assets and has been in business for at least three years, or by a company that has revenues of $6 million for 3 years.

If you decide to buy penny stocks, you must understand that the securities being bought have not been approved or disapproved by the Securities and Exchange Commission. Moreover, the Securities and Exchange Commission has not passed upon the fairness or the merits of this transaction nor upon the accuracy or adequacy of the information contained in any prospectus or any other information provided by an issuer or a broker or a dealer.

AFS does NOT provide any advice. As our customer, you are making unsolicited trades and must understand that you are responsible for your own transactions.

For more information regarding Penny Stocks please refer to: http://www.sec.gov/investor/schedule15g.htm

 
Mutual Fund Breakpoint Discounts and Other Disclosures Relating to Mutual Fund and Money Fund Fees and Revenue Sharing

Before investing in mutual funds, it is important that you understand the sales charges, expenses, and management fees that you will be charged as well as the breakpoint discounts to which you may be entitled. Understanding these charges and breakpoint discounts will assist you in identifying the best investment for your particular needs and may help you to reduce the cost of your investment. This section will give you general background information about these charges and discounts; however, sales charges, expenses, management fees, and breakpoint discounts vary from mutual fund to mutual fund. Therefore, you should discuss these matters with your investment professional and review each mutual fund's prospects and statement of additional information (which are available from your investment professional) to obtain the specific information regarding the charges and breakpoint discounts associated with a particular mutual fund. Many mutual funds waive "front-end" sales charges for accounts maintained as a "rollover" individual retirement account or as an investment option in a qualified retirement plan. Please, refer to the applicable fund prospectus, see your investment professional or call AFS at 1-800-890-3200 for further information.

 
Sales Charges

Investors who purchase mutual funds must make certain choices, including which funds to purchase and which share class is most advantageous in light of their specific investing needs. Each mutual fund has a specified investment strategy. You need to consider whether the mutual fund's investment strategy is compatible with your investment objectives. Additionally, many mutual funds offer different share classes. Although each share class represents a similar interest in the mutual fund's portfolio, the mutual fund will charge you different fees and expenses depending upon your choice of share class. As a general rule, Class A shares carry a "front-end" sales charge or "load" that is deducted from your investment at the time you buy the fund shares. This sales charge is a percentage of your total purchase. As explained below, many mutual funds offer volume discounts to the front end sales charge assessed on Class A shares at certain predetermined levels of investment, which are called "breakpoint discounts". In contrast, Class B and C shares usually do not carry any front-end sales charges. Instead, investors who purchase Class B or C shares pay asset-based sales charges, which may be higher or lower than the charges associated with Class A shares. Investors that purchase Class B or C shares may also be required to pay a sales charge known as a contingent deferred sales charge when they sell their shares, depending upon the rules of the particular mutual fund. This is known as a "back-end" sales charge or "load".

 
Disclosures: Day-Trading Risk Disclosure Statement
 
Day-Trading Risk Disclosure Statement

You should consider the following points before engaging in a day-trading strategy. For purposes of this notice, a "day-trading strategy" means an overall trading strategy characterized by the regular transmission by a customer of intra-day orders to effect both purchase and sale transactions in the same security or securities.

Day trading can be extremely risky. Day trading generally is not appropriate for someone of limited resources and limited investment or trading experience and low risk tolerance. You should be prepared to lose all of the funds that you use for day trading. In particular, you should not fund day-trading activities with retirement savings, student loans, second mortgages, emergency funds, funds set aside for purposes such as education or home ownership, or funds required to meet your living expenses. Further, certain evidence indicates that an investment of less than $50,000 will significantly impair the ability of a day trader to make a profit. Of course, an investment of $50,000 or more will in no way guarantee success.

Be cautious of claims of large profits from day trading. You should be wary of advertisements or other statements that emphasize the potential for large profits in day trading. Day trading can also lead to large and immediate financial losses.

Day trading requires knowledge of securities markets. Day trading requires in-depth knowledge of the securities markets and trading techniques and strategies. In attempting to profit through day trading, you must compete with professional, licensed traders employed by securities firms. You should have appropriate experience before engaging in day trading.

Day trading requires knowledge of a firm's operations. You should be familiar with a securities firm's business practices, including the operation of the firm's order execution systems and procedures. Under certain market conditions, you may find it difficult or impossible to liquidate a position quickly at a reasonable price. This can occur, for example, when the market for a stock suddenly drops, or if trading is halted due to recent news events or unusual trading activity. The more volatile a stock is, the greater the likelihood that problems may be encountered in executing a transaction. In addition to normal market risks, you may experience losses due to system failures.

Day trading will generate substantial commissions, even if the per trade cost is low. Day trading involves aggressive trading, and generally you will pay commissions on each trade. The total daily commissions that you pay on your trades will add to your losses or significantly reduce your earnings. For instance, assuming that a trade costs $16 and an average of 29 transactions are conducted per day, an investor would need to generate an annual profit of $111,360 just to cover commission expenses.

Day trading on margin or short selling may result in losses beyond your initial investment. When you day trade with funds borrowed from a firm or someone else, you can lose more than the funds you originally placed at risk. A decline in the value of the securities that are purchased may require you to provide additional funds to the firm to avoid the forced sale of those securities or other securities in your account. Short selling as part of your day-trading strategy also may lead to extraordinary losses, because you may have to purchase a stock at a very high price in order to cover a short position.

Potential Registration Requirements. Persons providing investment advice for others or managing securities accounts for others may need to register as either an "Investment Advisor" under the Investment Advisors Act of 1940 or a "Broker" or "Dealer" under the Securities Exchange Act of 1934. Such activities may also trigger state registration requirements.

 
Breakpoint Discounts

Most mutual funds offer investors a variety of ways to qualify for breakpoint discounts on the sales charge associated with the purchase of Class A shares. In general, most mutual funds provide breakpoint discounts to investors who make large purchases at one time. The extent of the discount depends upon the size of the purchase. Generally, as the amount of the purchase increases, the percentage used to determine the sales load decreases. In fact, the entire sales charge may be waived for investors that make very large purchases of Class A shares. Mutual fund prospectuses contain tables that illustrate the available breakpoint discounts and the investment levels at which breakpoint discounts apply. Additionally, most mutual funds allow investors to qualify for breakpoint discounts based upon current holdings from prior purchases through Rights of Accumulation and from future purchases based upon Letters of Intent. Mutual funds have different rules regarding the availability of Rights of Accumulation and Letters of Intent. Therefore, you should discuss these matters with your investment professional and review the mutual fund's prospectus and statement of additional information to determine the specific terms upon which a mutual fund offers Rights of Accumulation or Letters of Intent.

Rights of Accumulation - Many mutual funds allow investors to count the value of previous purchases of the same fund, or another fund within the same fund family, with the value of the current purchase to qualify for breakpoint discounts. Moreover, mutual funds may allow investors to count existing holdings in multiple Accounts, such as individual retirement Accounts (IRAs) or Accounts at other financial organizations to qualify for breakpoint discounts. Therefore, if you have Accounts at other financial organizations and wish to take advantage of the balances in these Accounts to qualify for a breakpoint discount, you must advise your investment professional about those balances. You may need to provide documentation establishing the holdings in those other Accounts to your investment professional if you wish to rely upon balances in Accounts at another firm.

In addition, many mutual funds allow investors to count the value of holdings in Accounts of certain related parties, such as spouses or children, to qualify for breakpoint discounts. Each mutual fund has different rules that govern when relatives may rely upon each other's holdings to qualify for breakpoint discounts. You should consult with your investment professional or review the mutual fund's prospectus or statement of additional information to determine what these rules are for the fund family in which you are investing. If you wish to rely upon the holdings of related parties to qualify for a breakpoint discount, you should advise your investment professional about these Accounts. You may need to provide documentation to your investment professional if you wish to rely upon balances in Accounts at another firm.

Mutual Funds also follow different rules to determine the value of existing holdings. Some funds use the current net asset value (NAV) of existing investments in determining whether an investor qualifies for a breakpoint discount. However, a small number of funds use the historical cost, which is the cost of the initial purchase, to determine eligibility for breakpoint discounts. If the mutual fund uses historical costs, you may need to provide Account records, such as confirmation statements or monthly statements, to qualify for a breakpoint discount based upon previous purchases. You should consult with your investment professional and review the mutual fund's prospectus and statement of additional information to determine whether the mutual fund uses either NAV or historical costs to determine breakpoint eligibility.

Letters of Intent - Most mutual funds allow investors to qualify for breakpoint discounts by signing a Letter of Intent, which commits the investor to purchasing a specified amount of Class A shares within a defined period of time, usually 13 months. For instance, if an investor plans to purchase $50,000 worth of Class A shares over a period of 13 months, but each individual purchase would not qualify for a breakpoint discount, the investor could sign a Letter of Intent at the time of the first purchase and receive the breakpoint discount associated with $50,000 investments on the first and all subsequent purchases. Additionally, some funds offer retroactive Letters of Intent that allow investors to rely upon purchases in the recent past to qualify for a breakpoint discount. However, if an investor fails to invest the amount required by the Letter of Intent, the fund is entitled to retroactively deduct the correct sales charges based upon the amount that the investor actually invested. If you intend to make several purchases within a 13 month period, you should consult your investment professional and the mutual fund prospectus to determine if it would be beneficial for you to sign a Letter of Intent. As you can see, understanding the availability of breakpoint discounts is important because it may allow you to purchase Class A shares at a lower price. The availability of breakpoint discounts may save you money and may also affect your decision regarding the appropriate share class in which to invest. Therefore, you should discuss the availability of breakpoint discounts with your investment professional and carefully review the mutual fund prospectus and its statement of additional information, which you can get from your investment professional, when choosing among the share classes offered by a mutual fund. If you wish to learn more about mutual fund share classes or mutual fund breakpoints, you can also review the investor alerts that are available on the FINRA web site at: www.finra.org/alert_mfclasses.htm and www.finra.org/alert_breakpoints.htm.

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