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Regulatory Information

iM Global Partner Asset Management - Regulated by the CSSF (Commission de Surveillance du Secteur Financier)

iM Global Partner Fund Management, LLC – Investment Adviser Firm Regulated by the SEC (Securities and Exchange Commission)

iM Global US Distributors – Broker Dealer Regulated by the FINRA (Financial Industry Regulatory Authority)

Some of the statements made by iM Global Partner Fund Management, LLC (“iMGPFM”) on the AdvisorIntelligence website and included in the marketing materials constitute a testimonial or endorsement of sponsors of the AdvisorIntelligence website and iMGPFM’s Partners. Such statements are considered a testimonial when the sponsor or Partner serves as a sub-adviser to an iMGP Fund and, as a result, iMGPFM is a client of the sponsor or Partner. Such statements are considered an endorsement when no sub-advisory relationship exists and iMGPFM is not a client of the sponsor or Partner.

iMGPFM has entered into contractual arrangements with sponsors of the AdvisorIntelligence website whereby the sponsors pay iMGPFM for the right to contribute content to the AdvisorIntelligence website, including information regarding the investment funds that the sponsors manage (“Participating Sponsor Funds” and together with the iMGP Funds and Partner Funds, the “Sponsored/Affiliated Funds”). The sponsors pay iMGPFM an annual sponsor fee of up to $25,000. The content available on AdvisorIntelligence includes, among other things, recommendations to invest in Sponsored/Affiliated Funds. These arrangements create a material conflict of interest because iMGPFM has an incentive to recommend the Sponsored/Affiliated Funds on AdvisorIntelligence. iMGPFM’s recommendations will likely result in additional investments in the Sponsored/Affiliated Funds, and indirectly, additional management fees, sponsorship fees and other benefits to iMGPFM or its affiliates. iMGPFM will not offset subscription fees by the amount of management fees or sponsorship fees collected from the Sponsored/Affiliated Funds or their affiliates, provided however that iMGPFM offers discounted subscription fees to subscribers that also invest in the iMGP Funds. To the extent the subscription fee is not waived, iMGPFM seeks to manage this conflict of interest by conducting investment due diligence and analysis on the funds that it recommends including the Sponsored/Affiliated Funds and by seeking to include, from time to time, multiple third-party fund recommendations for each asset class which may include but are not limited to the Sponsored/Affiliated Funds. It is iMGPFM’s policy not to take into account any funds’ arrangements with iMGPFM in deciding which funds to research or recommend.

iMGPFM serves as investment adviser to the iMGP Funds. In addition, iM Square SAS (“iM Square”), a beneficial owner of iMGPFM, has a direct or indirect ownership interest in certain Partners employed as sub-advisers to the iMGP Funds. While iM Square holds only a minority interest in these Partners, it is entitled to receive a portion of the investment manager’s gross revenues. This results in a material conflict of interest as iMGPFM has an incentive to recommend that these Partners serve as a sub-adviser to an iMGP Fund instead of a third-party firm. This conflict is managed by the Independent Trustees of the iMGP Funds who review the non-controlling nature and structure of iM Square’s investment in the Partners on an annual basis. This ensures that any such arrangement are at arm’s-length and fairly reflects the services provided by the Partners.