ACCOUNT DISCLOSURES

These disclosures provide you with important information about the products, services, and policies
that apply to your account. Please review this information carefully and keep them for your
permanent records.

Account Disclosures
Please review this important information about your account.

700 - Regulation Best Interest Disclosure

671 - Advisory Program Disclosures, II, WT
671 - Subadvisory Disclosures, II, WT
565 - Privacy Statement
569 - General Acct Agreement and Disclosure Doc
572 - Schedule of Fees, WellsTrade
574 - Cash Sweep Program Disclosure Statement,WFA
591 - Traditional IRA Custody Disclosure

594551 (Rev 02 - 05/20)

Regulation Best Interest Disclosure
This disclosure summarizes important information concerning the scope and terms of the brokerage services we offer and
details the material facts relating to conflicts of interest that arise through our delivery of brokerage services to you. Our goal is
to provide you with the information you need to make informed investment decisions. We encourage you to review this
information carefully, along with any applicable account agreement(s), disclosure documentation, or other materials you receive
from us. We reference various other documents throughout this disclosure, which have either been or will be provided to you as
applicable, based on you establishing a brokerage account, or engaging in certain brokerage investment activities with us. If
you would like a copy of any of these documents, please ask us. You should contact us promptly either in writing or by phone if
you do not fully understand this or any other disclosure we provide you, including any questions you have concerning the
essential facts of your brokerage relationship with us, or our conflicts of interest. As you review this information, we would like to
remind you that Wells Fargo Advisors (or WFA) is a trade name for Wells Fargo Clearing Services, LLC (WFCS), which is
registered with the U.S. Securities and Exchange Commission (SEC) as a broker-dealer and an investment adviser, providing
both brokerage services and investment advisory services, and a separate non-bank affiliate with Wells Fargo. For the ease of
discussion, this Disclosure uses Wells Fargo Advisors or “we,” “our,” and “us” to refer to all of those brokerage operations and
the term “financial advisors” to refer to our registered representatives. The term “affiliates” means any entity that is controlled
by, or controls, or is under common control with Wells Fargo Advisors, and includes Wells Fargo Bank, N.A. WFCS is also
affiliated with Wells Fargo Advisors Financial Network, LLC, a broker-dealer also providing advisory and brokerage services.
Both WFCS and Wells Fargo Advisors Financial Network, LLC use the trade name Wells Fargo Advisors. Each affiliate is a
separate legal entity. The term “client,” “you,” and “your” are used throughout this Disclosure to refer collectively to the
person(s) or organization(s) who engage us for brokerage services. Our brokerage services are the primary focus of this
disclosure. Please carefully review and consider the information in each section below.

Brokerage Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 2

Brokerage Service Models and Product Availability . . . . . . . . . . . . . . . . . . Page 4
Brokerage Fees and Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 6
Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15
Additional Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21

Important Information to Consider Before Reading Further

As you read the information in this disclosure, it is important for you to consider and understand the following:
• This disclosure is intended to comply with our obligations under Regulation Best Interest (Rule 15/-1 under the Securities
and Exchange Act of 1934), and, in certain cases, with other regulatory disclosure requirements.
• This disclosure does not otherwise change, alter or modify our other obligations under the federal securities laws, nor does
this disclosure otherwise change, alter or modify the terms and conditions of any client agreement(s) you enter into with us.

• Our obligations under Regulation Best Interest apply only when we recommend a type of account, a securities transaction
in your brokerage account, an investment strategy involving securities in your brokerage account, or recommend that you
roll over or transfer assets from one type of account to another (i.e., a workplace retirement plan account to an IRA). Our
obligations under Regulation Best Interest do not extend to other dealings we have with you, including when we execute
transactions where we have not made a recommendation, where you deviate from our recommendation(s), how we market
securities and our services, or in determining the fees we charge.
• Our obligations under Regulation Best Interest do not extend beyond a particular recommendation, nor do they create an
ongoing duty to you, or impose on us any duty to monitor your brokerage account or to monitor specific investments in
your brokerage account.

Investment and Insurance Products are:

• Not Insured by the FDIC or Any Federal Government Agency
• Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate
• Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested
Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC (WFCS), a registered broker-dealer and non-bank affiliate of
Wells Fargo & Company. WellsTrade® accounts are offered through WFCS.
594020 (Rev 06 - 07/22) Page 1 of 22
Brokerage Services
When you establish a brokerage account with us, you have the ability to buy, sell and hold investments in your account. The
primary service we provide is our transaction execution capability. We also provide other incidental services such as custody of
your assets, research reports, and recommendations to buy, sell, or hold assets.

We execute purchases and sales on your behalf, as directed by you. Please consider that we can act as agent for you and
execute your trades in the market or with another customer, this is referred to as an “agency trade,” or we can act as a principal
and trade with you for our own account or for the account of one of our affiliates, this is referred to as “principal trade.” When we
trade on a principal basis, you are buying from or selling to our firm’s inventory account. When we execute transactions as
principal, we earn a markup or markdown from the then prevailing market price of the security. In addition, we may make a
profit (or a loss) on the difference between the price at which we purchased the security and the price at which we sell it to you,
known as a dealer spread. As a result, we may make more on a principal transaction than on an agency transaction. We can
earn a profit on agency and principal trades. We will not tell you in advance or seek your consent to act as agent or principal for
a given trade. We will inform you of any profit earned on principal trades where required under applicable law. We will also
disclose on your trade confirmation whether we acted as agent or principal, along with trade details such as security symbol or
CUSIP, quantity purchased or sold, and price, upon completion of the trade.

Cash and Margin Accounts

We provide brokerage services through either a cash brokerage account or margin brokerage account, based on your eligibility
and selection. In a cash brokerage account, you must pay for your purchases in full at the time of purchase. In a margin
brokerage account, you must eventually pay for your purchases in full, but we can lend you funds at the time of purchase to
cover all or a part of your transaction. This is generally referred to as a “margin loan.” The portion of the purchase price we loan
you is secured by securities in your account, also referred to as “collateral.” You will incur interest costs as a result of your
margin activity. While many securities are eligible to be used as collateral for a margin loan, some assets are not available for
margin collateral purposes. Your margin brokerage account can also be used to borrow against eligible securities. Given that a
margin brokerage account has specific eligibility requirements, unique costs, and governing regulatory requirements, you must
execute a separate margin agreement with us before engaging in margin brokerage activity. Included with your margin
agreement is a copy of the Wells Fargo Advisors Margin Disclosure Statement. This statement contains important information
you should understand and consider before establishing a margin brokerage relationship with us. For more information on our
margin brokerage services, contact a financial advisor or refer to our Margin Disclosure Statement available at
wellsfargoadvisors.com under Legal Disclosures.

Other Brokerage Account Types

We offer many different brokerage account types including individual and joint accounts, custodial accounts, Delivery Versus
Payment (DVP) accounts, estate and trust accounts, partnership accounts, 529 Plan accounts, Coverdell Education Saving
Accounts (ESAs), individual retirement accounts (“IRAs”), and other types of retirement accounts.

Direct at Provider Accounts

Please consider that certain types of investments and accounts, (which are not limited to but may include certain existing 529
Plan accounts, 403(b) accounts and SIMPLE IRAs) are in some cases not held with us. These accounts are generally
described as “Direct at Provider Accounts” and are typically held instead at (i) the firm that manages the 529 Plan, or (ii) the
mutual fund company or mutual fund company transfer agent that offers the fund or retirement plan account.

For these Direct at Provider accounts that are not held with us, we typically assign an internal account number for our own
recordkeeping and regulatory purposes. This account number is for our internal use and typically cannot be used for deposits or
transactions. Funds given to us for investment in 529 Plans not maintained on our brokerage platform (i.e., Direct at Provider
Accounts) must be made payable to the provider. We cannot accept any funds made payable to us in relation to such accounts.
Any such funds we receive will be returned to you at your current address of record. You will be responsible for all costs and
losses, if any, resulting from such actions including lost interest and costs of disbursement, which may include, without limit,
reasonable attorneys' fees. No account statements, participant recordkeeping, accounting services, discrimination testing, tax
reporting, or plan document amendment services will be provided to you by us for these accounts. Further, we may assist you
with the initial selection of a Direct at Provider Account and any initial investment selections that you make, and we may assist
you with subsequent investment decisions. You will receive additional information about our obligations concerning Direct at
Provider Accounts in your account agreement(s) and related disclosure documents when you establish a brokerage account.

594020 (Rev 06 - 07/22) Page 2 of 22

Incidental Brokerage Services and Brokerage Recommendations
Within your brokerage account, in addition to our trade execution services, we also provide other incidental services such as
custody of your assets, research reports, and recommendations to buy, sell, or hold assets. When we recommend a type of
account, a securities transaction or investment strategy involving securities in your brokerage account, or recommend that you
roll over or transfer assets from one type of account to another (i.e., a workplace retirement plan account to an IRA), we act in
our capacity as a broker-dealer unless otherwise stated at the time of the recommendation. Any such statement will be made
orally to you. Moreover, you should understand that when we act in a brokerage capacity, with the exception of investment
advice we provide to retirement accounts governed by the Employee Retirement Income Security Act (“ERISA”) and/or the
Internal Revenue Code (“Code”), no recommendation that we make is intended to, nor should you consider it, to form the
primary basis for your investment decision(s). You will exercise your own independent judgment in determining whether to act
on our recommendations. We are not your investment adviser or fiduciary unless we have expressly agreed to act in such a
capacity with you in writing. Further, while we may consider information about your tax status that you provide to us as one
component of your investment profile, we do not provide tax advice. We encourage you to speak with a tax professional or tax
advisor regarding tax considerations or tax implications of your brokerage activity.

Beginning February 1, 2022, when we provide “investment advice,” as defined under Title I of ERISA and/or the Code, to you
regarding your retirement plan account, IRA or ESA, we are fiduciaries within the meaning of ERISA and/or the Code, as
applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests,
so when we operate as a fiduciary for your retirement account(s) we operate under a special rule, PTE 2020-02, that requires
us to act in your best interest and not put our interest ahead of yours. To the extent that particular communications to you or
activities are considered "investment education" or otherwise non-fiduciary under ERISA, we are not a fiduciary in connection
with such communications or activities.

Please know that you can choose to accept or reject any recommendation. You should carefully consider that the way we make
money creates some conflicts with your interests. These conflicts are addressed throughout this disclosure, most notably in the
Conflicts of interest section, and are further described in your account agreement(s) and other disclosure documentation we
provide in connection with your brokerage account. You should understand and ask us about these conflicts because they can
affect the recommendations we provide you.

Brokerage Account Monitoring and Investment Monitoring

It is your responsibility to monitor the investments in your brokerage account, and we encourage you to do so regularly. We will
not monitor your brokerage account or monitor investments within your brokerage account. While we can choose to provide you
with periodic reports that help you evaluate your current asset allocation as it relates to your investment goals and objectives,
these reports do not monitor specific investment holdings and should not be construed as a recommendation to buy, sell, or
hold any particular securities in your account. When we offer these services and information, we do so as a courtesy to you.
Upon request, we will review such reports with you and can provide you with specific investment recommendations, but we are
not under a particular obligation to do so. If you prefer ongoing monitoring of your investments, you should speak with a
financial advisor about whether an advisory relationship with us is appropriate for you.

Understanding Risk
While we will take reasonable care in developing and making recommendations to you, investing in securities involves risk, and
you may lose money, including your entire investment capital. Further, there is no guarantee that you will meet your investment
goals, or that our recommended investment strategy will perform as anticipated. Please consult any available offering
documents for any security we recommend for a discussion of risks associated with the product. We can provide those
documents to you, or help you to find them. Further, for certain products we recommend, you will receive additional product
disclosure documents (or Product Disclosure Statements) that contain additional risk and related disclosure details.

You should also consider that some investments involve more risk than other investments. Higher-Risk investments have the
potential for higher returns but also for significant losses. The lower your “risk tolerance,” meaning the amount of risk or loss you
are willing and able to accept in order to achieve your investment goals, the more we encourage you to avoid higher-risk
investments, as these investments pose the potential for significant losses.

594020 (Rev 06 - 07/22) Page 3 of 22

To help address these risks, we align investor risk tolerances with investment needs to offer you 10 investment objectives from
which to choose. You should select the investment objective and risk tolerance best aligned with your brokerage account goals
and needs. Investment goals typically have different time horizons and different income and growth objectives. Generally,
investment goals are on a spectrum. Risk tolerance also varies and we measure it on a continuum that increases from
“Conservative” to “Moderate” to “Aggressive,” and finally “Trading and Speculation.” You should consider these differences
before selecting the investment objective and risk tolerance associated with your brokerage account(s). For more information
concerning our available investment objective options, contact a financial advisor.

Basis for Brokerage Recommendations

When making a brokerage recommendation, we begin by gaining an understanding of your financial situation, investment
objectives and goals, and tolerance for investment risk. This is commonly known as your investment profile and includes
information that you disclose to us such as your income, age, number of dependents, net worth, liquid net worth, investment
experience, investment preference, and time horizon. Your investor profile information provides us with a framework for
evaluating which of the investment strategies and individual securities to recommend to you based on the risks, rewards and
costs of the investment security or strategy, and in light on your investor profile. You should understand that, while we consider
reasonably available alternatives with similar investment objectives where appropriate in making a recommendation to you,
there is no single “best” investment for any particular situation. We do not evaluate every possible alternative available at our
firm or in the marketplace in making a recommendation. You make the ultimate decision whether to follow our
recommendations to buy, sell, or hold securities in your account, and it is your responsibility to notify us of any changes to your
investor profile.

Brokerage Service Models and Product Availability

At Wells Fargo Advisors, there are three service models through which we may provide brokerage services to you. Each
brokerage service model provides a distinct way for you to interact and invest with us, and features specific product options and
product availability limitations. Our brokerage service models are designed to satisfy the investment needs, financial
complexities and personal preferences of our clients. These service models include:
1. Brokerage service through a dedicated financial advisor or team of financial advisors
2. Phone-Based brokerage service with our centralized team of financial advisors
3. Self-directed online brokerage service through our WellsTrade® platform

You should understand that we generally only recommend investments that are available on our brokerage platform. We
periodically review investment products to determine those products we make available. Our product review is performed at
both the product category level and at the individual investment or security level, as we deem necessary. Not all investment
products available in the marketplace are offered on our brokerage platform. Moreover, the availability of an investment product
(or products) through one of our brokerage service models does not mean that the same product or products will be available
across all of our brokerage service models. You should understand that each brokerage service model has its own unique
product availability. Also, we are not obligated to provide access to all products, product structures or share classes offered by a
given product sponsor, nor do we offer all or the least expensive products in the marketplace. Keep in mind that you can buy
and sell some of the products we offer at a lower cost to you through a self-directed online brokerage account, through another
broker-dealer, or by accessing certain brokerage products directly from the product sponsor. Product sponsors include mutual
fund complexes and other asset management firms. You should also understand that we can limit, and we do limit your
purchase of specific investment products by your documented investment objective, investor profile, account type, and other
factors, at our discretion. For example, beginning February 1, 2022, we currently do not permit certain principal trades (e.g.,
equity initial public offerings, equity follow-on offerings, new-issued preferred stocks, and certain closed-end funds) in retirement
accounts, including IRAs and ESAs. We encourage you to carefully consider our brokerage service models, and associated
product availability, as described below.

Dedicated Financial Advisor (or Team of Dedicated Financial Advisors)

When you receive brokerage services through a dedicated relationship with a financial advisor or team of financial advisors,
also referred to as a dedicated financial advisor brokerage service relationship or “full-service relationship,” your financial
advisor(s) works with you to understand your investment needs, goals and expectations, based on your unique investor profile.
You have the ability to interact with your financial advisor(s) exclusively. When working with a dedicated financial advisor, you
have the option to meet face-to-face and have access to a broad range of investment products and services available on our
brokerage platform. This includes equities, fixed income investments, alternative investments, options, investment company
products, syndicate transactions and other products and services we make available to you. For a current list of available
investment products, speak with a financial advisor.

594020 (Rev 06 - 07/22) Page 4 of 22

When you work with a dedicated financial advisor(s), you can choose to enable your brokerage account for online trading
access. As a dedicated financial advisor brokerage client, online trading enablement allows you to place your own equity,
option, and no-load mutual funds trades. Please note that online trading enablement is not available for retirement accounts. If
you participate in online trading enablement, you will receive additional information concerning fees, costs and features of this
offering through your enrollment guide.

Please consider that a dedicated financial advisor can, at the financial advisor’s discretion, initiate a change in the brokerage
service model available to your account. Your brokerage account can be reassigned to another associate in the financial
advisor’s office or a related office, assigned to our centralized team of phone-based financial advisors, or assigned to our
WellsTrade self-directed online brokerage service. You will receive a written notice from us informing you of the planned change
in your brokerage service model along with additional information concerning your brokerage account options. You will also
enter into an updated account agreement(s) and receive disclosure documentation as necessary.

Centralized Team of Phone-Based Financial Advisors

Brokerage services are also delivered through our centralized team of phone-based financial advisors. As compared to working
with a dedicated financial advisor(s) exclusively, you will communicate with any number of financial advisors in this centralized
group. Instead of face-to-face interactions, our team of centralized financial advisors are accessible by phone and e-mail. It is
important to understand that not all of the brokerage products and services offered by us are available to you through our
centralized team of phone-based financial advisors. Available brokerage products include:

• Equities
• Fixed Income investments
• Mutual funds
• Exchange-traded funds (ETFs)
• Annuities
Please consider that while investment products from each of these product categories are available to you, the
recommendations provided by our centralized team of phone-based financial advisors are typically limited to a specific menu of
pooled investments. This menu includes certain mutual funds and exchange-traded funds only. Certain brokerage products and
services are unavailable through our centralized team of phone-based financial advisors. This includes:

• Alternative investments (including private capital, hedge funds and Real Estate Investment Trusts (REITs))
• Derivatives (futures or options)
• Insurance products
• Employer sponsored retirement plan accounts
• Syndicate offerings
• Lending and banking services and credit line products

At our discretion, we transition accounts from our centralized phone-based team of financial advisors to our WellsTrade self-
directed online brokerage service model. You will receive a notice from us informing you of the planned change in your
brokerage service model along with additional information concerning your brokerage account options. You will also enter into
an updated account agreement(s) and receive disclosure documentation as necessary.

WellsTrade®
Our WellsTrade brokerage account provides access to self-directed online investing. If you establish a WellsTrade account, or
have your existing brokerage account transferred to WellsTrade, we will not provide you advice or investment
recommendations. Instead, a WellsTrade brokerage account gives you the flexibility and convenience of managing your
investments on your terms. You are responsible for the investment decisions you make in your WellsTrade account. Through
WellsTrade, you can purchase and sell stocks, exchange-traded funds (ETFs), options, and no-load mutual funds online, and
have access to purchase a limited menu of fixed income investments by phone. Further, WellsTrade offers $0 trades for stocks
(excluding penny stocks) and exchange-traded funds (ETFs). WellsTrade also provides access to research tools and market
news to help you manage your account. For more information about WellsTrade, visit wellsfargoadvisors.com.

594020 (Rev 06 - 07/22) Page 5 of 22

Account Minimums and Activity Requirements
There is no minimum initial account balance required to open a brokerage account with us. However, if you either fail to fund
your account or do not return the account opening documents, as required, your account will be closed. In addition, if your
account has a zero balance and no trading activity, we can close your account. Also, for brokerage IRAs, if you fail to maintain
minimum on-going balance requirements as specified in your IRA account agreement(s), your brokerage account will be closed.
You should also understand that our dedicated financial advisors, in some cases, establish their own requirements for the
brokerage accounts they service. For example, a dedicated financial advisor can choose to service only those brokerage
account clients who satisfy account-specific or total household asset requirements. Specific minimum asset requirements are
disclosed to you orally by the financial advisor.

Brokerage Fees and Costs

It is important to consider that while a brokerage account relationship can be a cost-effective way of investing, it is not for
everyone given the fees and costs involved.

Account and Service Fees

You will pay fees for various operational services provided for your brokerage account. These fees are set at least annually and
are detailed in the Additional resources section of this document. Additionally, these fees are communicated to you through
information included in your account opening documents and other notifications. Some fees do not apply to all account types
and can be waived or discounted. Please consider that we permit financial advisors to discount certain account and service fees
and charges at their discretion. Financial advisors are not obligated to discount account or service fees. You should speak with
a financial advisor and consult your account opening document(s) for details. Also, you should understand that based on the
brokerage service model you choose, the same or similar products, accounts and services will vary in the fees and costs
charged to you.

Transaction-Based Charges
You will pay transaction-based charges for trades you decide to enter into, such as buying and selling stocks, bonds, Exchange
Traded Products (ETPs), mutual funds, annuity contracts, exercising options and other investment purchases and sales. These
transaction-based charges are generally referred to as a “commission,” “commission equivalent,” “markup,” “markdown,” “dealer
spread,” “sales load,” or a “sales charge.” Transaction-Based charges are based on a variety of factors, including, but not
limited to:

• Underlying product selection

• Your brokerage service model and account type
• Size of your transaction and/or overall value of your account
• Frequency of your trade activity
• Available discounts and/or fee waivers

Please consider that we permit financial advisors to discount certain transaction-based charges at their discretion. Financial
advisors are not obligated to discount any transaction-based charges. Speak with a financial advisor for details.

Direct and Indirect Compensation

You should also consider that we receive direct and indirect compensation in connection with your brokerage account. Direct
compensation is taken directly from the affected account. Indirect compensation is compensation paid in ways other than
directly from the account; however, indirect compensation will impact the value of the associated investments in your account
as detailed in the Product Fees and Costs information below.

Commission Schedule
Note: The sections below include our commission schedules and additional product-level fee and cost information for dedicated
financial advisors and our centralized team of phone-based financial advisors, and excludes WellsTrade®.

594020 (Rev 06 - 07/22) Page 6 of 22

Stocks/Equities, Rights, Warrants, Secondary Market Closed-End Funds (CEFs), Exchange Traded Products (ETPs), and
Options - The schedule below details the maximum commission charged to you and received by us for trades of stocks/equities,
rights, warrants, secondary market closed-end funds (CEFs), exchange traded products (ETPs) and options transactions.
Detailed information concerning your specific commission charge will be provided in your trade confirmation, which we will send
you at or prior to completion of your transaction.

Principal or Options Premium Band % of Principal

$1 - $4,999.99 3.90%
$5,000 - $9,999.99 2.90%
$10,000 - $49,999.99 2.15%
$50,000 - $99,999.99 1.50%
$100,000 - $249,999.99 1.20%
$250,000 - $499,999.99 1.00%
$500,000 - $999,999.99 0.85%
$1,000,000 - $9,999,999.99 0.70%
$10,000,000 - $24,999,999.99 0.35%
$25,000,000 - $49,999,999.99 0.20%
$50,000,000+ 0.10% (max $1,000,000)

• Minimum is $55, not to exceed 15% of principal value

• Schedule for share price < $1: 19% of principal value, not to exceed $75.00 or 5%, whichever is greater
• Schedule price maximum is $1,000,000.

Product Fees and Costs

Below you will find additional fee, cost and related disclosure details for the products and services available to retail investors
on our brokerage platform. Please note that the disclosure information provided below is further supported and supplemented
by various other disclosures that we also provide to you from time to time. In other words, we provide layers of disclosure to
support our recommendations and to help ensure you make informed investment decisions. These additional disclosures
combined with the information in this disclosure are designed to comply with our Regulation Best Interest Disclosure obligation.
The additional types of disclosure documents we provide include, but are not limited to the following:

• Offering Documents - When you purchase certain investments, such as mutual funds, you will receive offering materials
such as a prospectus, Statement of Additional Information (SAI) or other product sponsor-provided materials. The timing
and manner of delivery of these documents is generally prescribed by regulation and varies by product.

• Product Disclosure Statement - For certain products we recommend (i.e., annuities and hedge funds), your financial
advisor, at or prior to the recommendation, will provide you a Product Disclosure Statement (or “Point of Sale Disclosure”)
developed by us. The Product Disclosure Statement will typically include additional product feature, cost and related
information. When applicable, Product Disclosure Statements are provided at the first recommendation of certain
products, but not provided at or prior to subsequent recommendations of the same type of product. In some cases, you
will be asked to sign the Product Disclosure Statement as evidence of delivery. In other cases, your signature will not be
required.

• Product Guides - For certain products we offer, you will receive product-specific information via a “Product Guide” or
similar product education document. These documents typically contain product risk, feature, fees/cost and conflicts
information. Product Guides may be included in your account agreement(s) (i.e., A Guide to Investing in Mutual Funds
and A Guide to Buying Annuities) and/or delivered to you by your financial advisor. When applicable, Product Guides are
provided at the first recommendation of certain products, but are not provided at or prior to subsequent recommendations
of the same type of product. You may request a copy of a Product Guide from your financial advisor or access our library
of Product Guides by visiting wellsfargoadvisors.com/guides.

• Trade Confirmation - When you execute a trade with us, we will send you a trade confirmation at or prior to the
completion of your transaction. The trade confirmation includes detailed information including security, trade date,
settlement date, amount and other trade-related information required under applicable law. Additionally, for certain
products, your trade confirmation will include other fee, cost and conflict disclosure information.

594020 (Rev 06 - 07/22) Page 7 of 22

We encourage you to review the product-specific fee and cost information included below along with any additional disclosures
we provide you.

Stocks/Equities
Common stock (also referred to an “an equity”) is a share of ownership in a company entitling the shareholder to vote at
shareholder meetings and receive dividends if and when dividends are issued. Stocks/equities are traded on exchanges and
over the counter. Accordingly, stocks/equities are subject to the Commission Schedule.

Additional Disclosure - When you execute a stock/equity transaction, we will send you a trade confirmation at or prior to
completion of your transaction.

Stock Rights and Warrants

Stock rights are instruments issued by companies to provide existing shareholders the opportunity and privilege to preserve
their fraction of corporate ownership by receiving additional shares of common stock when a new issue is offered. Stock
warrants are long-term instruments that allow an existing shareholder to purchase additional shares of stock at a discounted
price (but typically a price above the then current market price of the common stock). Stock rights and warrants are subject to
the Commission Schedule.

Additional Disclosure - When you execute a stock rights or stock warrants transaction, we will send you a trade confirmation
at or prior to completion of your transaction.

Secondary Market Debt Securities, Preferred Securities and Certificates of Deposit (CDs)
A debt security refers to a debt instrument, such as a government bond, corporate bond, certificate of deposit (CD), municipal
bond, or preferred stock, that can be bought or sold between two parties and has basic defined terms such as the amount
borrowed, the interest rate, the maturity date and the renewal date. For debt securities, including preferred securities and CDs,
we can apply a charge (i.e., markup) of 2% to 3% for longer-dated debt, and 0% to 2% for short-dated debt from the prevailing
market price of the security or investment on secondary market transactions. Additionally, we typically incur gains (or losses) on
positions we hold in inventory in response to market movements or other events that impact the value of the securities we own.

Additional Disclosure - When you execute a transaction in debt securities, preferred securities, and CDs, we will send you a
trade confirmation at or prior to completion of your transaction.

Mutual Funds
A mutual fund is a company that pools money from many investors and invests it in a single portfolio of securities that is
professionally managed. The mutual fund company owns the underlying investments, and the individual investors own shares
of the fund. Mutual funds have a variety of fees and expenses as detailed below. Through our dedicated financial advisors and
centralized team of phone-based financial advisors, you may purchase A Shares, C Shares and no-load shares, as we make
available to you. In addition, if you maintain other share classes in your account, you may continue to hold and liquidate those
shares at your discretion.

• Front-End Sales Charges - Front-End sales charges are paid to us, including your financial advisor, when you purchase
a fund. The front-end sales charge is deducted from the initial investment on certain share classes. This charge typically
ranges from 1.00% to 5.75%. Some purchases qualify for a reduced front-end sales charge due to breakpoint discounts
based on the amount of transaction and rights of accumulation (ROA). In addition, some purchases qualify for a sales
charge waiver based on the type of account, and/or certain qualifications within the account, as permitted by prospectus;
however, in some cases, the prospectus will give us discretion concerning whether to allow a given sales charge waiver.
You should also consider and understand that we do not offer all share classes available by prospectus.

• Contingent Deferred Sales Charges (CDSC) - A CDSC, or back-end load, is a charge you pay upon withdrawal of
money from a fund prior to the end of the fund’s CDSC period. CDSC charges typically range from 0.25% to 2% for Class
A and Class C Shares, and can range up to two years. CDSC charges typically range from 0.25% to 5% for Class B
shares and can range up to six years. This charge typically is associated with share classes that do not have a front-end
sales charge (i.e., Class C mutual fund share classes), but other share classes can feature CDSC charges as well.

594020 (Rev 06 - 07/22) Page 8 of 22

 • 12b-1 Fees Charges (CDSC) - Annual 12b-1 fees, also known as “trails,” are paid by the fund and paid to us out of fund
assets each year for marketing and distribution expenses. These payments are subject to a distribution and servicing
arrangement to cover distribution expenses and sometimes shareholder service expenses we provide on the fund’s
behalf. Typically these fees range between 0.05% and 0.35% for Class A Shares and Class B Shares, and these fees
can range between 0.05% and 1% for Class C shares.

• Shareholder Service Fees - Shareholder service fees are paid to us to respond to investor inquiries and provide
investors with information about their investments. These fees are asset-based fees charged by the mutual fund complex.
When applicable by prospectus, typically these fees range between 0.05% and 0.35% for Class A Shares and Class B
Shares, and these fees can range between 0.05% and 1% for Class C shares.

• Revenue Sharing - Revenue-Sharing fees are paid to us for providing continuing due diligence, training, operations,
systems support, and marketing to financial advisors and investors with respect to mutual fund complexes and their
funds. We receive revenue sharing from mutual fund complexes in connection with your account assets through
arrangements we have with them. Revenue sharing is not passed on to financial advisors. Revenue-Sharing fees are
usually paid by the fund’s investment advisor, or an affiliate, as a percentage of our aggregate value of client assets
invested in the funds. In certain instances, revenue sharing is paid as a percentage of annual new sales to clients, or as a
combination of a percentage of new sales and a percentage of aggregate client assets. The percentage amounts are
typically established in terms of basis points, which are equal to one one-hundredth of 1%. We receive different revenue-
sharing rates from each mutual fund complex, and in some cases receive different revenue sharing rates for certain funds
and/or share classes within a particular mutual fund complex. There are also some mutual fund complexes that do not
pay revenue sharing to us. Mutual fund complexes pay us revenue-sharing compensation at an annual rate ranging from
one to 20 basis points on aggregate client assets. These rates are up to 10 basis points on new sales of the mutual
funds. Certain mutual fund complexes pay us a negotiated, fixed annual amount for revenue sharing, regardless of the
amount of assets held in client accounts or in new sales to clients.

• Networking and Omnibus Fees - “Networking and omnibus fees” are financial services industry terms intended to
describe payments we receive from mutual fund complexes for performing various administrative and operational
activities on behalf of the mutual fund complexes whose shares we distribute. This activity includes, but is not limited to
trade processing, distribution of client confirmations and the provision of client statements and tax information, as well as
the various technology and related supports needed to facilitate these activities. We are responsible for all costs
associated with networking and omnibus services we perform including, but not limited to, technology and personnel.
Networking and omnibus fees are not passed on to financial advisors. The compensation paid for networking and
omnibus services is negotiated separately with each fund complex under arrangements we have with them and the
amount varies depending on the mutual fund complex and each individual fund and/or share class. These fees are
mutually exclusive in nature, so a single mutual fund position would not be charged networking and omnibus fees, only
one or the other. There are also some mutual fund complexes that do not pay networking or omnibus fees to us. If you
own multiple funds in one mutual fund complex, we generally receive networking or omnibus compensation for each
individual fund. We receive networking compensation based on a dollar amount per year, per client account with an
individual fund or based on a percentage of assets in a fund. Networking compensation is paid at a rate between $2 to
$12 per year per client position or at a rate between five to 10 basis points on assets. Compensation paid to us for
omnibus services are generally higher than networking compensation because we are required to perform a more
extensive array of services to clients and the fund for omnibus accounts. We receive omnibus compensation based on a
dollar amount per year per client position with an individual fund or based on a percentage of assets in a fund. Omnibus
compensation is paid at a rate between $8.50 to $25 per year per client position or at a rate between two to 30 basis
points on assets, as agreed upon by the mutual fund complex and us. Depending on asset levels, basis point pricing can
result in higher or lower compensation than a per-position fee. These fees are indirectly borne by the fund client (i.e.,
you), in that we do not bill or collect these fees directly from you.

• Data Agreements - We provide aggregated sales information related to our client accounts to certain mutual fund
complexes. These payments are not attributable to a particular account or holdings nor does the service include any
information identifiable to a particular account or holding. For these services, we receive payments from mutual fund
complexes. Payments range from $450,000 to $550,000.These payments are paid to and retained by us and are not
directly shared with financial advisors.

Additional Disclosure - In your account agreement(s) and related documentation, you will receive additional information about
our mutual fund offerings, the costs of mutual fund investing, the compensation we receive when you purchase mutual funds,
and the risks of investing in mutual funds via our mutual fund Product Guide. Further, when we recommend a mutual fund, you
will receive a copy of the mutual fund prospectus and any related disclosures. In addition, when you purchase a mutual fund,
we will send you a trade confirmation at or prior to completion of your transaction.

594020 (Rev 06 - 07/22) Page 9 of 22

529 Plans
529 Plans, also referred to as 529 educational savings plans, or qualified, state tuition programs, are professionally managed,
tax-advantaged portfolios that enable individuals to set aside funds for educational purposes.

For a 529 Plan or funds, you are subject to sales charges and account fees. We also receive administrative fees, 12b-1 fees,
and investment management fees. If your state of residence offers a 529 Plan, your in-state 529 Plan can have lower expenses
as compared to an out-of-state 529 Plan. Further, some in-state 529 Plans offer certain tax benefits to you that are not available
when you purchase an out-of-state 529 Plan. Ask you financial advisor for details and consult your tax advisor for guidance.

When you establish a 529 Plan through a financial advisor, you will typically pay higher fees and costs than if you establish your
529 Plan account directly with the 529 Plan provider. Refer to the 529 Plan's offering documents for a listing of fees and
expenses. You should understand that we receive a sales concession of 1% to 5.75% from the 529 Plan provider on 529 Plan
transactions. You should also consider that mutual fund complexes may allow investors to aggregate 529 Plan and mutual fund
holdings in related accounts to reach a breakpoint. This is called Rights of Accumulation (ROA). Advise your financial advisor of
your mutual fund holdings to obtain ROA. Further, some companies allow a Letter of Intent (LOI) that indicates an intention to
invest a certain amount over time to reach a breakpoint. Refer to the program disclosure or offering document(s) for details. As
a reminder, we do not provide access to all products, product structures or share classes offered by a given product sponsor,
including 529 Plans.

Additional Disclosure - When we recommend and you establish a 529 Plan account with us, you will receive a 529 Plan
Account Disclosure Statement, a 529 Plan Product Guide, the program disclosure or offering document(s) for the mutual fund-
sub-accounts, and the 529 Plan sponsor’s specific documents containing additional product disclosure information. For 529
Plan accounts maintained on our systems, we will also send you a trade confirmation for each transaction, prior to or upon
completion of your transaction. For 529 Plan accounts maintained Direct at Provider, you should refer to any additional
confirmation of sale or other disclosure document(s) you receive from the 529 Plan provider.

Exchange Traded Products (ETPs)

Exchange Traded Products (ETPs) are securities that derive their value form a basket of securities such as stocks, bonds,
commodities, or indices, and are traded similar to individual stocks on an exchange. Accordingly, ETPs are subject to the
Commission Schedule. ETPs also carry built-in operating expenses that can affect the ETP’s return.

When we recommend an Exchange Traded Product (ETP), you will receive a copy of the ETP’s prospectus and related
disclosures where applicable. For ETPs you should consider that we provide aggregated sales data for a fee to ETF sponsors
relating specifically to such sponsor’s ETFs. The annual payment is $650,000 for ETF sponsors purchasing such data. This
presents a conflict of interest for us and our financial advisors to the extent it leads us to focus more on sponsors that purchase
the ETF data over those that do not. Our financial advisors do not receive any additional compensation for recommending ETFs
from sponsors that purchase the data. In addition to the transaction-based commissions received by us and your financial
advisor, we receive certain non-transaction related payments from ETP product sponsors, including reimbursements for training
and education and payments for ETP data related to sales activities conducted by us with respect to ETPs of such ETP product
sponsors. Please note that these compensation arrangements are described in the prospectus and the Statement of Additional
Information (SAI), a supplementary document to the prospectus, for each ETP offered by us.

Additional Disclosure - When you purchase and ETP, we will send you a trade confirmation at or prior to completion of your
transaction.

Secondary-Market Closed-End Funds

Secondary-Market closed-end funds are investment companies that are managed pools of investments, generally offered in a
fixed number of shares, and traded on a stock exchange. Secondary-Market closed-end funds are subject to the Commission
Schedule. You should also consider that closed-end funds feature built-in internal expenses that affect the fund’s return. These
expenses are used to pay for the investment manager, trading commissions, legal and administrative costs and other expenses
of the fund. These internal expenses are deducted directly out of the fund itself through a reduction in the Net Asset Value
(NAV) of the fund.

Additional Disclosure - When you execute a secondary-market closed-end fund transaction, we will send you a trade
confirmation at or prior to completion of your transaction.

594020 (Rev 06 - 07/22) Page 10 of 22

Options
Options are contracts giving the purchaser the right to buy or sell a security, such as a stock, at a fixed price within a specific
period of time. Options transactions are subject to the Commission Schedule.

Additional Disclosure - Prior to engaging in options activity, you will execute an options agreement with us and your financial
advisor will provide you with a copy of the Characteristics & Risk of Standardized Options disclosure. When you execute an
options transaction, we will send you a trade confirmation at or prior to completion of your transaction.

Variable Annuities
An annuity is a contract between you (the contract owner) and an insurance company. A variable annuity is a type of annuity
contract designed to produce income payments tied to the performance of an investment portfolio that you select. Variable
annuities are available in several share classes. We offer B shares for brokerage account clients. B-Share annuities feature a
commission charge and other fees and charges as described below.

• Mortality and Expense (M&E) Charge - This charge may also be called a Product Fee. This charge is a percentage of
your account value and ranges from 1.15% to 1.45% for B shares.

• Administrative Fees - These fees can be a flat annual amount of $25 to $30 or a percent of the account value (typically
0.15%). These fees are often waived for larger account values.

• Subaccount Expenses - These fees are annual charges on the underlying investments in a variable annuity and can
include management fees and 12b-1 fees. These expenses vary depending on the type of investment and can range
from 0.25% to 2.00% or more. On average, the cost for subaccounts is between 0.90% and 1.10%.

• Surrender Charge - A surrender charge is sometimes referred to as a contingent deferred sales charge (CDSC). These
typically last from five to seven years, depending on the terms of the contract. If you surrender your contract before this
period is up you may be subject to this charge. Surrender charges are typically higher in early years, from 7% to 9%, and
decline over time.

• Optional Feature Charge - If you purchase an optional feature, such as a living or death benefit, you will pay an annual
charge for that feature. Charges can range from 0.50% to 1.40% or more depending on the feature chosen.

Under arrangements with insurance companies, we receive commissions from the insurance companies for the sale of
annuities, as well as trail commissions. Trail commissions are considered indirect compensation. Commissions and trails paid to
us vary by product type and vary by insurance carrier. These commission costs are not paid by you in addition to the fees and
charges listed above. Commission options range from .95% to 5.00%, but no more than 4.00% will be paid to your financial
advisor, while trail commission options range from 0.10% to 1.00%. A select number of annuity contracts are no longer
available for sale, but are held in existing client accounts. The commission options on these contracts typically range from 2% to
6%, but can be as high as 8.40%. Trail commission options range from .10% to 1.00%, but can be as high as 1.30%. For more
information regarding these types of contracts, please contact your financial advisor. Some variable annuity contracts contain
subaccounts that are managed or sub-advised by Allspring Global Investments. Allspring Global Investments receives
management fees for assets held in those funds. For sales of variable annuities, we receive revenue sharing from the carriers
on both new sales and AUM, which is considered indirect compensation. We receive up to 20 basis points for all deposits into
existing contracts or newly established contracts. In addition, we currently receive between three and five basis points on AUM
beginning in the 13th month. On certain pre-existing contracts that are no longer available for sale, we receive 2.5 to 10 basis
points on AUM for contracts in force greater than 13 months. For the fees above, financial advisors are not directly
compensated from the sources mentioned; however, they do receive commission and trail payments. In addition to the
commissions described above, we receive marketing support payments from many of the insurance companies whose
annuities we sell. These payments are made by the insurance company, an affiliate of the insurance company, or the
investment management company that serves as manager of the underlying investment options for variable annuities. The
payments can be used to pay for training and educational conferences and meetings for our financial advisors, company
wholesalers, various administrative and recordkeeping costs, educational meetings and seminars for our current and
prospective clients, and due-diligence evaluations of the claims-paying ability of the insurance companies whose annuities we
sell. None of these payments are passed on to your financial advisor as commissions or ongoing payments. However, the
payments can be used to fund some of the general benefits provided to your financial advisor, as noted.

594020 (Rev 06 - 07/22) Page 11 of 22

Additional Disclosure - In your account agreement(s) and related documentation, you will receive additional information about
annuities, the compensation we receive when you purchase an annuity, and our conflicts of interests related to annuity
recommendations. In addition, upon your initial purchase of an annuity, your financial advisor will provide you with a copy of the
appropriate annuity Product Disclosure Statement. Subsequent investment or purchase in an existing annuity will not be
accompanied by the Product Disclosure Statement, but you may request a copy from your financial advisor. Lastly, when you
purchase an annuity, we will send you a trade confirmation at or prior to completion of your transaction.

Variable Life Insurance

A life insurance policy is a contract between the owner of the policy and a life insurance company. When you buy a life
insurance policy, you name the person to be insured (who may be you or someone else) and you select the amount of
insurance you desire. You also name a beneficiary. When the person who is insured dies, the life insurance company will pay
the in force amount of insurance (less any outstanding loans) to the person or persons you named as beneficiaries. This is
referred to as a “death benefit.” Variable life insurance provides a death benefit as well as an accumulation feature where a
portion of the premium paid is invested in a variety of separate accounts, similar to mutual funds, chosen by the policy owner.
Variable life insurance features the following charges; however, for specific details about your policy, please refer to your
insurance contract:

• Cost of Insurance - This amount is based on the amount of death benefit at risk to the insurance company (death
benefit minus accumulated fund) and is not guaranteed; however, it cannot exceed the maximum rates guaranteed in the
policy.

• Cost of Rider - This amount is what the insurance company charges for any additional coverages, commonly referred to
as riders, on the policy such as spouse/child coverage, long-term care, lapse protection, return of premium, etc. Rider
costs vary; however, it cannot exceed the maximum rate guaranteed in the policy.

• Premium Load - The insurance company applies this to each premium payment to cover state and federal taxes and
premium based expenses. It is usually applied as a percentage of premium collected and is determined by each carrier.
This charge is generally 0% to 20% of premium.

• Administrative Expenses - These charges are assessed by the insurance company and include the cost of issuing the
policy, premium billing, collection, policy value calculation, confirmations and periodic reports. These charges are stated
in the policy and are generally guaranteed to not increase for the life of the policy.

• Fund Expenses - This is specific to each fund available, varies among funds and can increase or decrease at the
discretion of the fund manager. These expense can range from 0.01% to 2.5%.

• Mortality & Expense Charge - This is a fee that compensates the insurance company for mortality risks and other
various risks and expenses it assumes. This charge is stated in the policy and not subject to change.

• Surrender Charge - This is an amount that the insurance company will deduct from the policy cash value if it is
canceled. This charge is on a sliding scale and can last from policy years 1 to 30 years from the issuance of the policy.

All of the applicable fees and charges for any policy should be provided to you in a hypothetical illustration and the prospectus.

Under agreements with insurance companies, we receive commissions from the insurance companies for the sale of insurance
policies, as well as excess premiums, renewals and trail commissions. These payments are considered indirect compensation.
Commissions, renewals and trails paid to us vary by product type and insurance carrier. The amount of commission varies by
carrier and is based on the type of underlying policy. Premiums in excess of the annual or target premium (typically referred to
as “excess premiums” will typically be paid at 1% to 5% of the amount paid. Ongoing payments, called “trail commissions,” of
generally 0.5% to 2% per year on invested assets that are held in the life insurance policy for more than one year and are set by
the insurance company. We can also receive ongoing compensation on the policy for subsequent premiums, also called
“renewal premiums,” paid after the first year. Renewal premiums typically pay compensation of 5% to 20% of the renewal
premium and is set by the insurance company. In addition to the commissions described above, we receive marketing support
payments from many of the insurance companies whose policies we sell. These payments may be used to pay for training and
educational conferences and meetings for our financial advisors, various administrative and recordkeeping costs, educational
meetings and seminars for our current and prospective clients, and due diligence evaluations of the claims-paying ability of the
insurance companies whose policies we sell. We can also receive up to $200,000 per insurance company for financial support
for educational seminars to pay for training and educational meetings for our financial advisors. These payments are not made
directly by you. They are paid by the insurance company, an affiliate of the insurance company, or the investment management
company that serves as manager of the underlying subaccount options for variable life or variable universal life insurance. None
of these payments are passed on to your financial advisor as commissions or ongoing payments.

594020 (Rev 06 - 07/22) Page 12 of 22

Additional Disclosure - When we recommend an insurance product and execute an insurance product transaction with you,
you will receive an insurance Product Disclosure Statement, any supplemental insurance Product Disclosure Statement (as
applicable), carrier application documents and applicable forms, prospectus (for variable life insurance products), and any other
required documents. Once an insurance offer is accepted by the carrier you will also receive the insurance policy and other
applicable carrier forms.

Market-Linked Investments
Market Linked Investments are investment vehicles whose value is derived from, or based on, an underlying market measure.
Market measures may include single equity or debt securities, indexes, commodities, interest rates, and/or foreign currencies,
as well as baskets of these market measures. Market Linked Investments are a type of a hybrid product. Market Linked
Investments typically have two components — (1) a note and (2) a derivative, which is often an option.
The note, in some instances, may pay interest at a specified rate and interval. The derivative component establishes payment
at maturity, which is based on a return calculation and the performance of the underlying market measure. For example, Market
Linked Investments may combine characteristics of debt and equity or debt and commodities.

Most Market Linked Investments have a fixed maturity and may or may not pay an interest rate or coupon rate. Market Linked
Investments also frequently cap or limit the upside participation in the market measure, particularly if the investment offers a full
return of principal at maturity, or an enhanced rate of interest. Any return of principal at maturity would be subject to the ability of
the issuer to make payments when due.

Market-Linked Investments’ primary market offering fees are comprised of our sales concession (or similar fee) and a
distribution expense fee for selling a Market-Linked Investment, and Well Fargo Securities (WFS’) (an affiliate) underwriting
expenses and projected profit for structuring and hedging the particular offering sold. These fees are based on a general
commission schedule. For Market-Linked Investments, our sales concession is customarily 0.5% to 2.5% and our distribution
expense fee is customarily 0.075% to 0.12%. WFS' underwriting expenses and projected profit for structuring and hedging are
customarily 0% to 4.75%.

Additional Disclosure - When we recommend Market-Linked Investments, including Market-Linked Certificates of Deposits,
you will receive the prospectus or other offering documents for the specific product. You will also receive a trade confirmation,
at or prior to completion of your transaction, that will include a Product Disclosure Statement and links to the Product Guides.

Alternative Investments
Alternative Investments are investment vehicles that do not align with conventional investment categories. We offer four
alternative investment products, as outlined below. Annual trails and placement fees paid to us, including financial advisors, will
vary based on the particular interest or share class selected. Below you will find the typical fees and expenses for the different
alternative investments we offer.
• Managed Futures/Commodities - Maximum placement fee of 0% to 2% with a 75 basis point trail.
• Hedge Funds - Maximum placement fee of 0% to 2% with a 75 basis point trail.
• Private Equity/Private Real Estate - Maximum placement fee of 0% to 2% with a 85 basis point trail.

We may also receive revenue sharing as indirect compensation for providing ongoing day-to-day marketing and sales support
to our Financial Advisors and clients with respect to Alternative Investment providers and their funds. Revenue sharing fees are
usually paid by the fund as a percentage of our aggregate value of assets invested in the funds. In certain instances, revenue
sharing may be paid as a percentage of annual new sales to clients, or as a combination of a percentage of new sales and a
percentage of aggregate client assets. The revenue sharing fees range from 0% to 0.30%.

Additional Disclosure - When we recommend an alternative investment, you will receive the appropriate offering documents,
subscription agreement and/or other required documents, the appropriate Product Disclosure Statement, and Product Guide
where applicable. In addition, we will send you a trade confirmation at or prior to completion of your transaction. Your trade
confirm will contain additional fee, cost and conflict disclosure information.

Unit Investment Trusts (UITs)

A Unit Investment Trust (UIT) is an investment company that generally purchases a portfolio of stocks, bonds, or other
securities. The portfolio is typically fixed and not actively managed or traded; the portfolio’s securities are held relatively
unchanged for the life of the UIT.

594020 (Rev 06 - 07/22) Page 13 of 22

The UIT prospectus includes a fee table that lists the charges you pay. UIT investors generally pay an initial sales charge, a
deferred sales charge, a creation and development fee, organizational costs, and an annual trust-operating expense. The
application of these charges can vary, depending on the sponsor, the length of the trust, and whether the UIT is an equity trust
or a fixed-income trust. In addition to the fees outlined in the prospectus, you can be assessed a transaction charge or an
administration fee for purchases and sales prior to maturity of unit investment trusts through us. Your financial advisor does not
receive compensation from the transaction charge or administration fee.
Our affiliates license indices to UIT sponsors and we and our affiliates directly receive licensing and portfolio consulting and
supervisory compensation from UIT sponsors. For participating in the underwriting of a fixed-income UIT, the provider may also
pay us a percentage of the accumulated profit that was made in purchasing the underlying bonds for the portfolio before the
initial deposit date of the UIT, as well as additional per unit sales concessions. In addition, when you purchase a fixed-income
UIT in the secondary market, the concession amount and rate may vary. Volume Sales Concession is paid to us as described in
each financial-services firm’s UIT prospectus. Volume Sales Concessions are additional revenue received by us based on the
volume of equity and fixed-income UIT sales. These payments are used for a number of purposes, including training and
educational conferences and meetings for our financial advisors, as well as for conducting due diligence on the trusts.

Additional Disclosure - When we recommend a UIT, you will receive the appropriate prospectus and/or marketing materials
containing specific product information. In addition, we will send you a trade confirmation at or prior to completion of your
transaction.

Brokered Certificates of Deposit (CDs)

Brokered CDs, or secondary CDs, are bought and sold between dealers and investors much like other fixed-income
instruments. Dealers trade the investments at a net cost, which includes their own spread, or profit, on the transaction. We
receive compensation in the form of a commission or markup from most transactions. For most purchases, a financial advisor’s
compensation is based on the dollar amount purchased or sold. We receive compensation for maintaining a secondary market
in CDs (although we are not required to do so) and for keeping an inventory on select CD offerings.

Additional Disclosure - When you purchase a brokered CD, we will send you a trade confirmation and Product Disclosure
Statement summary at or prior to completion of your transaction.

Cash Sweep Program/Bank Deposit Sweep/Other Float Compensation

Our brokerage services include a Cash Sweep Program feature. Brokerage account clients can provide consent, through the
general account opening agreement, to use our Cash Sweep Program. Under our Cash Sweep Program, uninvested cash
balances in your account are automatically swept into interest bearing deposit accounts (“Standard Bank Deposit Sweep” and
"Expanded Bank Deposit Sweep," together the “Bank Deposit Sweep Programs”) or, if available, stable-value money market
mutual funds (“Money Market Funds”), or such other sweep arrangements made available to you (collectively “Cash Sweep
Vehicles”), until these balances are invested by you or otherwise needed to satisfy obligations arising in connection with your
account. The Cash Sweep Program is subject to the terms and conditions of the Cash Sweep Program Disclosure Statement,
which you will receive. Prior to receipt of the general account opening documents, cash deposited in your account and not
otherwise invested, will be held as a free credit balance and not placed in the Cash Sweep Program until written consent is
provided to participate in our Cash Sweep Program. While any cash remains in free credit balance, we will retain any interest
earned on assets awaiting investment or disbursement. You understand and agree that this interest (generally referred to as
"float") will be retained by us as additional compensation for the provision of services with respect to the account. The amount
of this benefit is based on the prevailing market rates on overnight investments. Except for retirement accounts, while any cash
remains in free credit balance, you will not earn any interest on such balances.

Syndicate
“Syndicate” refers to the issuance and sell of new issue securities, including Equity Initial Public Offerings and follow-on
offerings, new issue preferred offerings, new issue Closed-End Funds (CEFs), and customized fixed income offerings. As part
of a syndicate transaction, your financial advisor will receive compensation in the form of a selling concession, which is paid by
the issuing company. Generally, the selling concession that the financial advisor receives is in the range of 0.5% to 3%. The
issuing company also pays management and structuring fees to the underwriter from 0.33% to 2%. Details of the management
and structuring fees, and selling concession are contained in the offering prospectus. If you invest in a new issue security
offering, you will purchase the offering at the Public Offering Price and will not be charged any direct and/or additional fees in
order to make that syndicate offering purchase.

594020 (Rev 06 - 07/22) Page 14 of 22

Additional Disclosure - When recommending a syndicate offering, we will provide you with the preliminary prospectus (where
required) or other offering documents for the specific product. You should consult the offering materials for fee, cost and
conflicts information. For new issue Closed-End Funds, you will also receive a Product Disclosure Statement. When you
execute a syndicate transaction, we will send you a trade confirmation at or prior to completion of your transaction.

Margin and Priority Credit Line

We receive interest payments when you carry a margin or Priority Credit Line (PCL) balance. Proceeds from margin loans can
be used to purchase securities and for other purposes. Proceeds from a PCL loan can be used for almost any purpose other
than to: purchase securities, invest in insurance products, refinance or repay margin, or repay any other loans used for security
purposes. The margin and PCL interest rates vary based on the Wall Street Journal (WSJ) Prime Rate and other factors such
as your assets with us and the amount of funds currently being borrowed. Financial advisors are not compensated on margin
but are compensated based on your Priority Credit Line debit balance. Thus, your financial advisor and we have a conflict of
interest to recommend Priority Credit Line over margin and for you to borrow at greater amounts. Information on interest rates
and how we calculate interest is proved to you when you open a margin or Priority Credit Line account. For information on
current rates and how rates are determined, review the disclosures provided with your margin or PCL agreement, or visit
wellsfargoadvisors.com/why-wells-fargo/products-services/lending/securities-based.htm.

Bank Product or Service Referrals

When we make bank product or service referrals to an affiliate, you will receive verbal and/or written disclosure as applicable.
Our financial advisors receive referral compensation or credit based on loans that are closed and funded or, for lines of credit,
on your debit balance. We thus have a conflict of interest in that your financial advisor and we make more money the greater
your debt. Compensation ranges from five to 75 basis points based on the underlying product and interest rate charged.

Conflicts of Interest
Conflicts of interest exist when we provide brokerage services to you. At Wells Fargo Advisors, our conflicts of interest are
typically the result of compensation structures and other financial arrangements between us, our financial advisors, our clients,
and third parties, as well as our and our affiliates’ roles in the financial markets. We offer a broad range of investment services
and products and we receive various forms of compensation from our clients, affiliated and non-affiliated product sponsors and
investment advisors, and other third parties as described above. Securities rules allow for us, our financial advisors, and our
affiliates to earn compensation when we provide brokerage services to you. However, the compensation that we and our
financial advisors receive from you varies based upon the product or service you purchase, which creates a financial incentive
to recommend investment products and services that generate greater compensation to us. While our conflicts of interest have
been disclosed throughout this document, below you will find additional information.

Compensation We Receive from Clients

• Transaction-Based Conflicts - In your brokerage account you pay certain fees (commissions and sales charges) in
connection with the buying and selling of each investment product. Where these fees apply, the more transactions you
enter into, the more compensation that we and your financial advisor receive. This compensation creates an incentive for
us to recommend that you trade more frequently, rather than hold, these investments. We also have an incentive to
recommend that you purchase investment products that carry higher fees, instead of products that carry lower fees.

• Principal Trading - We trade certain products on a principal basis, meaning you are buying from or selling to our firm’s
inventory account. When we execute transactions as principal, we earn a markup or markdown from the then prevailing
market price of the security. In addition, we may make a profit (or a loss) on the difference between the price at which we
purchased the security and the price at which we sell it to you. As a result, we can make more on a principal transaction
than on an agency transaction.

• Interest Payments - We receive interest payments when you carry a margin or Priority Credit Line (PCL) balance. This
interest rate varies based on the WSJ Prime Rate and other factors such as your assets with WFA and the amount of
funds currently being borrowed. Financial advisors are not compensated on margin but are compensated based on your
Priority Credit Line debit balance. Thus, while we have a conflict if your financial advisor recommends a margin loan, both
your financial advisor and we have a conflict of interest to recommend Priority Credit Line over margin and for you to
borrow at greater amounts. Information on interest rates and how we calculate interest is provided to you when you open
a margin or Priority Credit Line account.

594020 (Rev 06 - 07/22) Page 15 of 22

 • Material, Non-Public Information and Other Confidential Information - We provide a broad range of services to our
clients. In connection with these services, we will from time to time, come into possession of sensitive, confidential and
material, non-public information about instruments, product sponsors, issuers, markets and products. Understand that we
are prohibited from improperly disclosing or using such information for or own benefit, our clients’ benefit, or for the
benefit of any other person, regardless of whether such other person is a client of ours. You should understand and
consider that this information, if disclosed, could affect your decision to buy, sell or hold an investment, but that we are
prohibited from communicating such information to you or using it for your benefit.

• Client Versus Client Conflicts - Financial advisors typically receive limited allocations to new and follow-on offerings.
This creates an incentive for financial advisors to favor certain clients over other clients, particularly those clients who
generate greater compensation for the financial advisor. Further, financial advisors have an incentive to provide different
levels of service to their clients, including providing preferential service to those clients who generate greater
compensation.

Account maintenance and other administrative fees - For the services we provide or make available to you with respect to your
brokerage account, we charge certain account maintenance and other administrative fees, including transfer, wire, or other
miscellaneous fees, as described in the fee schedule provided to you on an annual basis. The higher the fees we charge, the
more we are compensated. See the Additional resources section of this document for details concerning these fees.

Compensation We Receive from Third Parties

We receive payments from third parties relating to developing and maintaining our product platform. These payments include
support for marketing and training of our financial advisors. Third-Party payments we receive can be based on new sales of
investment products, creating an incentive for us to recommend you buy and sell, rather than hold, investments. In other cases,
these payments are made on an ongoing basis as a percentage of invested assets, creating an incentive for us to recommend
that you buy and hold investments (or continue to invest through a third-party manager or adviser).

The total amount of payments we receive varies from product to product, and varies with respect to the third-party investment
management products we recommend. It also varies from the compensation we receive in connection with other products and
services we make available to you, including advisory services. We have an incentive to recommend investment products and
services that generate greater payments to us. This compensation generally represents an expense embedded in the
investment products and services that is borne by investors, even where it is not paid by the product sponsor and not directly
from the investment product or other fees you pay. The types of third-party compensation we receive include:

• Revenue Sharing - Many product sponsors pay us for selling their products, including marketing support, based on our
total sales and/or total client assets in their products. Product sponsors pay us different amounts. Revenue sharing
payments are not passed on to financial advisors.

• Trail Compensation - Trails are generally associated with mutual funds and annuities. They are set by the mutual fund
complex or annuity company and published in the offering. This ongoing compensation is received by us and shared with
our financial advisors. This compensation (commonly known as trails, service fees or Rule 12b-1 fees in the case of
mutual funds) is typically paid from the assets of the investment product under a distribution or servicing arrangement
and is calculated as an annual percentage of invested assets. The amount of this compensation varies from product to
product. We have an incentive to recommend that you purchase and hold interests in products that pay us higher trails.

• Networking and Omnibus Fees - Product sponsors pay us and our affiliates networking and omnibus fees for account
and administrative services we provide on their behalf for our clients. These payments are calculated as an annual
percentage of the amount of assets invested, or based on positions, or as a combination of both. The compensation paid
for networking and omnibus services is negotiated separately with each product sponsor and varies from product to
product. We have an incentive to make available on our platform products that pay greater amounts of networking and
omnibus fees. Your financial advisor does not share in this compensation.

• Unaffiliated Program Bank Compensation - We and our affiliates benefit financially from cash balances held at
unaffiliated Program Banks in the Expanded Bank Deposit Sweep. In the case of non-retirement accounts, each affiliated
and unaffiliated Program Bank in the Expanded Bank Deposit Sweep Program will pay us an amount not to exceed a
percentage (equivalent to Federal Funds Target plus 30 basis points (0.30%)) of the daily total non-retirement deposit
balances at that Program Bank, however the amount of that fee may vary from one Program Bank to the next. This
amount includes our fee and interest payable to participating accounts in the Expanded Bank Deposit Sweep. More
information about our compensation from the Bank Deposit Sweep Programs is described in the Cash Sweep Program
Disclosure Statement, which you receive when you open your account and is also available at
wellsfargoadvisors.com/financial-services/account-services/cash-sweep.htm.

594020 (Rev 06 - 07/22) Page 16 of 22

 • Training and Education - As noted throughout this disclosure, we work closely with many product and service sponsors
who provide training and education financial support to us in return for costs we incur in conducting comprehensive
training and educational meetings for our financial advisors. These meetings or events are held to educate financial
advisors on product characteristics, business building ideas, successful client interaction strategies as well as various
other topics. In some cases, this compensation is applied to cover costs our financial advisors incur to obtain professional
designations. In addition, certain vendors provide free or discounted research or other vendor products and services,
which can assist our financial advisors with providing services to you. Likewise, product providers will reimburse us for
expenses incurred by individual branch offices in connection with conducting training and educational meetings,
conferences, or seminars for financial advisors and clients. Also, financial advisors receive promotional items, meals or
entertainment or other non-cash compensation from product sponsors. Although training and education reimbursements
are not related to individual transactions or assets held in client accounts, it is important to understand that, due to the
total number of product sponsors whose products are offered by us, it is not possible for all companies to participate in a
single meeting or event. Consequently, those product sponsors that do participate in training or educational meetings,
seminars or other events gain an opportunity to build relationships with financial advisors; these relationships could lead
to sales of that particular company’s products. We receive varying amounts of training and education reimbursements
from companies. The training and education reimbursements for centrally organized events and vendor products or
services vary from $25,000 to $1,000,000 per company annually. There are also some companies that do not provide
any training and education compensation to us.

• Data Agreements - We provide aggregated sales information related to our client accounts to certain mutual fund
complexes. These payments are not attributable to a particular account or holdings nor does the service include any
information identifiable to a particular account or holding. For these services, we receive payments from mutual fund
complexes. Payments range from $450,000 to $550,000. These payments are paid to and retained by us and are not
directly shared with financial advisors.

• Additional Compensation from Product Sponsors and Other Third Parties - We and our financial advisors,
associates, employees, and agents receive additional compensation from product sponsors and other third parties
including:

• Gifts and awards, an occasional dinner or ticket to a sporting event.

• Reimbursement from product sponsors for research and technology-related costs, such as those to build systems,
tools, and new features to aid in servicing clients.
• Additionally, we and our affiliates receive compensation from product sponsors to provide aggregate sales data.

The amount of these payments is not dependent or related to the level of assets you or any other of our clients invest in
or with the product sponsor.

• Product Share Classes - Some product sponsors offer multiple structures of the same product (i.e., mutual fund share
classes) with each option having a unique expense structure, and some having lower costs to you as compared to others.
We are incentivized to make available those share classes or other product structures that will generate the highest
compensation to us. We do not offer all share classes. For instance, we do not in every instance offer the cheapest share
class available. Check with the product sponsor for details.

• Payment for Order Flow - WFA does not have payment for order flow agreements with other broker-dealers for
executing equity orders, however we may receive payment from national stock exchanges when routing non-marketable
limit orders that are subsequently executed (orders that “make” liquidity). WFA does not accept payment for equity orders
executed with market makers or broker-dealer affiliates. For option orders, WFA may receive compensation for directing
option orders to specific market centers for execution, and such compensation includes cash payments as well as
noncash items, such as discounts, rebates, reductions, or credits against fees that would otherwise be payable in full. For
additional information, please reference the “Payment for Order Flow” section of your General Account Agreement and
Disclosure Document.

Compensation Related to Our Affiliates

We are a non-bank affiliate of Wells Fargo & Company (“Wells Fargo”). We are not a bank or thrift and are a separate and
distinct corporate entity from our affiliated banks. We have a number of related persons that provide investment management
and related financial services. The identity of these related persons and summary of the products and services follows.

594020 (Rev 06 - 07/22) Page 17 of 22

 • Wells Fargo also provides retail brokerage and investment advisory services through Wells Fargo Advisors Financial
Network, LLC ("WFAFN").

• Wells Fargo holds a less than ten percent ownership interest in Allspring Global Investments (“Allspring”), a trade name
used to describe the asset management businesses of Allspring Global Investments Holdings, LLC. Allspring includes
the following companies: Allspring Funds Management, LLC, the investment adviser to each of the mutual funds within
the Allspring Global family of funds; Allspring Funds Distributor, LLC, the principal underwriter of the Allspring Global
mutual funds; and Allspring Global Investments, LLC, an investment adviser to pooled investment vehicles and
separately managed accounts.

• Additionally, Wells Fargo and its affiliates, including Wells Fargo Clearing Services, LLC, (collectively “Wells Fargo”) will
receive compensation from Allspring for the distribution, administrative, research, and operational services that they
provide to Allspring and funds managed or distributed by Allspring. While Wells Fargo has no role in the management of
Allspring, Wells Fargo & Company's equity ownership in Allspring and Wells Fargo's servicing arrangements with
Allspring may create a conflict of interest for Wells Fargo when evaluating or recommending products managed or
distributed by Allspring, including mutual funds and sweep vehicles, as Wells Fargo may benefit financially from
increased sales of such products to a greater extent than it would for sales of other third-party products in which Wells
Fargo does not have a similar financial interest.

• Wells Fargo Investment Institute, Inc. ("WFII") (known prior to November 1, 2014 as Alternative Strategies Group, Inc.
and before that as Wachovia Alternatives Strategies, Inc.) is a registered investment advisor and wholly owned subsidiary
of Wells Fargo & Company that provides advisory services and research to WFA.

• Wells Fargo Bank, N.A. offers various deposit and lending services.

As you consider the role and nature of the affiliate relationships noted above, you should review and consider the following
conflicts of interest:
• Cash Sweep Program - If you have elected to participate in our Cash Sweep Program, the uninvested cash balances in
your brokerage account are automatically deposited into one or more of our affiliated banks in our Bank Deposit Sweep
Programs or swept into a money market fund. We and our affiliates receive fees and benefits for services provided in
connection with the Cash Sweep Program, and we have an incentive to recommend that you use, and maintain cash
positions in, the sweep vehicles that are more profitable to us and our affiliates. Your financial advisor is compensated
based on total assets in your account(s), including assets held in the Cash Sweep Program.

Where your brokerage account’s sweep vehicle is a money market mutual fund, we and our affiliates receive trails,
investment management, service fees and other compensation. The types and amount of these fees vary depending on
the actual money market mutual fund (and class thereof) used. Mutual fund complexes typically offer multiple share
classes with different levels of fees and expenses. When selecting the share class for the Money Market Fund used as a
Cash Sweep Vehicle, we do not, in all instances, select the share class with the lowest fees that is available from the
fund company and these decisions are influenced by the additional compensation we receive in connection with your
account's Money Market Fund holdings. The use of a more expensive share class of a Money Market Fund as a Cash
Sweep Vehicle will negatively impact your overall investment returns.

Where your brokerage account's sweep vehicle consists of deposits in our affiliated banks, we and our affiliates, including
the affiliated banks, benefit financially from such cash deposits. As with other depository institutions, the profitability of our
affiliated banks is determined in large part by the difference or "spread" between the interest they pay on deposit
accounts and the interest or other income they earn on loans, investments and other assets. The participation of our
affiliated banks as a sweep option for your brokerage account is expected to increase their respective deposits and,
accordingly, overall profits. While we have policies and procedures designed to pay a reasonable rate of interest based
on prevailing interest rates at other or similar financial services firms, our rates are not always the highest interest rates
available.

In addition, Wells Fargo Advisors will receive compensation from the Affiliated Banks in an amount not to exceed a
percentage (equivalent to Federal Funds Target plus 30 basis points (0.30%)) of the daily total deposit balances at the
Affiliated Banks. Our management personnel and other employees, including our affiliates, receive incentive
compensation based in part on sweep assets at an affiliated bank or the profitability of the affiliated banks and their joint
parent company, Wells Fargo & Company. We have a conflict of interest because it influences both the amount you are
paid in interest and the amount our associates and employees receive in compensation on these sweep deposits. This
compensation is subject to change and we can waive all or any part of this fee at any time without notice.

594020 (Rev 06 - 07/22) Page 18 of 22

 • Margin, Priority Credit Line and Affiliated Bank Lending Programs - There are conflicts of interest when we
recommend that you use a loan secured by your WFA account assets as collateral. These conflicts exist with a margin
loan, Priority Credit Line from WFA, or with any of our affiliated bank lending programs that may be available to you from
an affiliate lender. Specifically, in the case of Priority Credit Line, we receive interest payments on the Priority Credit Line
loan, and your Financial Advisor receives compensation up to 75 basis points but could be lower depending on how
much of an interest rate discount you are provided. Financial Advisors receive greater compensation the more you
borrow under a Priority Credit Line or affiliate bank lending program, and they receive greater compensation if you are
charged a higher interest rate. Financial Advisors, therefore, have an incentive to encourage you to go into greater debt
and to discourage interest rate discounts. We receive interest payments on margin loans, but Financial Advisors are not
compensated on the margin loans. FA compensation may vary by product, which means the FA's compensation could be
negatively impacted by discounting.

We or our affiliate lender have a lien on your account assets that are used as collateral for the loan. We or our affiliate
lender will act to protect ourselves as lender in connection with the loan, and this may be contrary to your interests and/or
investment objectives. This lien also creates a conflict of interest with respect to the recommendations we make to you.
For example, your Financial Advisor may recommend that you allocate your investments to your account with a lien
rather than to another account without such a lien. Also, your Financial Advisor may recommend an investment solely to
minimize the risk of loss with respect to the collateral.

As noted above, except in the case of margin, your Financial Advisor is compensated based on your debit balance. This
means your Financial Advisor is compensated based on your borrowing, rather than if you were to liquidate assets held in
the WFA account to meet your funding needs. Furthermore, your Financial Advisor will receive a reduction in
compensation by recommending that you reduce your outstanding loan balance.

Please review the disclosures provided with your margin, Priority Credit Line, or affiliate bank lending program
agreement, or visit wellsfargoadvisors.com/why-wells-fargo/products-services/lending/securities-based.htm.

• Compensation for Other Services - We and our affiliates offer brokerage, investment advisory and banking services to
a wide variety of retail and institutional clients, including product sponsors and their products/investment vehicles. This
presents a conflict of interest because, depending on the particular client account, we and our financial advisors can earn
more or less revenue from products and investment vehicles in brokerage, advisory, and bank accounts as a result of
recommending that you maintain investments through such accounts.

• Other Affiliate Relations - We are a subsidiary of Wells Fargo & Company (“Wells Fargo”), a diversified, community-
based financial services company that provides banking, insurance, investment, mortgage, consumer and commercial
financial services through multiple subsidiaries and affiliates. These relationships provide financial and other benefits to
Wells Fargo. During the course of annual business planning, business with our affiliates is included in establishing our
business objectives. We have an incentive to hire affiliates to provide certain products and services. Our affiliates
typically pay us and our financial advisors for referring potential clients to them; we typically pay our affiliates for referring
potential clients to us and our financial advisors. These referral payments can be based upon the revenue generated by
any accounts established by referred clients or as otherwise agreed to by the affiliated parties.

Referral payments between affiliates will not result in any additional charges to clients. When you purchase a proprietary
product or service, which are products and services managed, issued, or sponsored by us or any of our affiliates, the
compensation to us and/or our affiliates can be greater than if you purchase a third party product. We and our affiliates
also share revenue in various forms, including, but not limited to, management credits and other, similar revenue sharing
arrangements. Consequently, we have an incentive to recommend investments in proprietary products and services.

We also receive direct compensation or indirect accounting credits in connection with the referral of certain business
among Wells Fargo & Company subsidiaries. These intra-company arrangements include payments or credits to us for
financial, distribution, administrative, and operational services that we provide to affiliates, their investment advisers, or
distributors.

• Compensation Related to Proprietary Products - Brokerage recommendations can include a recommendation to

invest in a product or service that is managed, issued or sponsored by us or our affiliates. We and our affiliates will
receive additional compensation or economic benefits from investments by you in such products, including, but not
limited to, management credits, service fees and similar revenue sharing arrangements. The compensation related to
these can be greater than similar products provided by third parties. Thus, we have an incentive to recommend
investments in proprietary/affiliated products.

594020 (Rev 06 - 07/22) Page 19 of 22

 • The Research We Provide - We have financial arrangements with several research providers and provide compensation
in exchange for such research. These research providers are both affiliates, including Wells Fargo Investment Institute,
Inc., a registered investment adviser that provides advisory services and research to Wells Fargo Advisors, Wells Fargo
Securities LLC, as well as unaffiliated third parties, each of which have different financial relationships with us. This
research is subject to conflicts of interest at the firm where it is produced, which can impair the objectiveness and quality
of the investment rating and opinion contained in the research. The provider conflicts are explained in the research itself,
while our conflicts are further detailed in documentation you receive from us along with the research we provide. You can
also access our conflicts information by visiting wellsfargoadvisors.com/researchdisclosures.

Wells Fargo Investment Institute, Inc. also provides research and strategy recommendations to our other affiliates. While
all affiliates have similar access to this research and those recommendations, due to the operational differences, manner
and size of accounts at affiliates, certain affiliates are able to implement and trade on this information prior to another
affiliate. The ability to implement and trade on research and recommendations first could give the clients of one of our
affiliates an advantage over you.

Compensation Related to Our Financial Advisors

Financial advisors are compensated in a variety of ways. Most financial advisors at Wells Fargo Advisors are compensated in
part, based on the percentage of revenue generated from sales of products and services to clients and/or total assets under
advisement, including brokerage account activity, as discussed above. This compensation varies by the product or service
associated with a brokerage recommendation. Financial advisors receive compensation based on Priority Credit Line balances.
However, no compensation based on Margin balances. Some of our financial advisors are compensated on a salary basis.

Typically, a financial advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion)
increases with production and asset levels. The same payout schedule is reduced when financial advisors discount certain
client fees and commissions, or client relationship asset levels are below minimums established by us. Financial advisors are
also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include
reaching certain production levels, tenure with the firm, client product mix, asset gathering, referrals to affiliates or other targets,
as well as compliance with our policies and procedures and meeting best business practices. Moreover, financial advisors
receive higher compensation for transactions involving client households that maintain greater amount of assets with us.

As a result, financial advisors have an incentive to provide brokerage recommendations that result in selling more investment
products and services, as well as investment products and services that carry higher fees. Financial advisors also have an
incentive to provide brokerage recommendations to gather more assets and to increase brokerage trading activity, and to
reduce the amount of discounts available to you.

Financial advisors have an incentive to recommend you rollover assets from a qualified retirement plan (QRP) to a brokerage
IRA, instead of recommending you maintain your assets in your QRP or pursue other transfer options available to you.

Brokerage accounts, unlike advisory accounts, do not feature an on-going fee based on assets under management. Financial
advisors are incentivized to recommend you establish a brokerage account, and also incentivized to transition your brokerage
services account to an advisory account to generate on-going revenue where your brokerage account has minimal activity.
Further, financial advisors are incentivized to recommend you transition your brokerage account to an advisory account after
you have already placed purchases resulting in commissions and/or other transaction-based brokerage fees. Financial advisors
also have an incentive to provide higher levels of service to those clients who generate the most fees.

• Recruitment Compensation - Recruitment compensation is provided to financial advisors who join our firm from another
financial firm. This compensation, which varies by financial advisor, typically has three components: 1) an up-front
payment, 2) a deferred compensation component; and 3) a back-end bonus arrangement based on new client assets
transitioned/gathered over a three-year period. This creates an incentive for the financial advisor to recommend the
transfer of assets to the firm to earn this compensation.
• Noncash Compensation - Noncash compensation is provided to financial advisors in the form of certain titles and/or
education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates,
such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor
and/or participate in educational meetings and recognition trips gain opportunities to build relations with financial
advisors, which could lead to sales of such product provider’s products. Financial advisors also receive promotional
items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per
vendor and $1,000 per year for meals per vendor.

594020 (Rev 06 - 07/22) Page 20 of 22

 • Personal Trading and Outside Business Activities - A conflict of interest can arise between our financial advisors and
other associates by virtue of their personal trading activities. Our financial advisor and associates’ personal trading
activities can adversely affect your orders, transactions and trading strategies. Also, financial advisors and other
associates can engage in outside activities (i.e., board memberships or directorships), or they themselves or close family
members can hold elected office that can create conflicts with you or with WFA.
• Charitable and Political Contributions - financial advisors and other associates can make political and charitable
contributions creating the perception that the financial advisor, the associate or the firm is seeking a quid pro quo
arrangement.

Conflicts of Interest Summary

This information is not intended to be an all-inclusive list of our conflicts but to provide you with material facts regarding our
conflicts of interest. In addition to this disclosure, conflicts of interest are also disclosed to you in your account agreement(s) and
disclosure documents, our product guides and other information we deliver to you or otherwise make available to you.

Additional Resources
Wells Fargo Advisors Form CRS
https://www.wellsfargoadvisors.com/disclosures/legal-disclosures.htm
Legal Disclosures
https://www.wellsfargoadvisors.com/disclosures/legal-disclosures.htm
Margin Disclosure
https://www.wellsfargoadvisors.com/disclosures/margin-disclosures.htm
Cash Sweep Program
https://www.wellsfargoadvisors.com/bw/forms/578326.pdf
Priority Credit Line Disclosure
https://www.wellsfargoadvisors.com/bw/forms/591496.pdf
Research Disclosures
https://www.wellsfargoadvisors.com/disclosures/research.htm
Investment Objectives and Risk Tolerance
https://www.wellsfargoadvisors.com/disclosures/guide-to-investing/investment-risk-tolerance.htm
Wells Fargo Advisors Product Guides
https://www.wellsfargoadvisors.com/disclosures/guide-to-investing.htm
Characteristics and Risks of Standardized Options
https://www.wellsfargoadvisors.com/doc-exit-page.htm?con=https://www.theocc.com/components/docs/riskstoc.pdf
Annual Operational Fee Schedule
https://www.wellsfargoadvisors.com/services/financial-advisor/relationship/fees-commissions.htm

Contact Us
Help Opening a New Account
1-866-224-5708
Monday - Friday: 8:30 am - 9:30 pm ET
Saturday: 8:30 am - 7:00 pm ET
Locate a Financial Advisor

Online Services & Access Online Support

1-877-879-2495
Email: onlinefeedback@wellsfargoadvisors.com

Help With an Existing Account

Contact your financial advisor or call us at the number below:
1-866-281-7436
Monday - Friday: 8:00 am - 12:00 am ET
Saturday: 8:00 am - 7:00 pm ET

594020 (Rev 06 - 07/22) Page 21 of 22

Non-US Clients
1-704-383-2127
Monday - Friday: 8:00 am - 8:00 pm ET
Office Locations

Mailing Address
Wells Fargo Advisors
One North Jefferson Ave.
St. Louis, MO 63103

594020 (Rev 06 - 07/22) Page 22 of 22

Wells Fargo Advisors U.S. Privacy Notice Rev. 1/2022

FACTS WHAT DOES WELLS FARGO ADVISORS (WFA) DO WITH YOUR PERSONAL INFORMATION?
Why? 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.

What? 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 employment information
• account balances and transaction history
• credit history and investment experience
How? 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 Wells Fargo Advisors
chooses to share; and whether you can limit this sharing.

Does WFA Can you limit this

Reasons we can share your personal information share? sharing?

For our everyday business purposes - such as to process your transactions, maintain your account(s), Yes No
respond to court orders and legal investigations, or report to credit bureaus
For our marketing purposes - with service providers we use to offer our products and services to you Yes No
(please see below to limit the ways in which we contact you)
For joint marketing with other financial companies No We don't share
For our affiliates' everyday business purposes - information about your transactions and experiences Yes No
For our affiliates' everyday business purposes - information about your creditworthiness Yes Yes
For our affiliates to market to you Yes Yes
For nonaffiliates to market to you No* We don't share
*If your financial advisor departs WFA and joins a non-affiliated securities broker-dealer with which WFA has
entered into an agreement regarding financial advisors changing firms, WFA may share with your financial
advisor certain limited contact information which will be used to solicit you to join the new firm. The only
information WFA will share is your name, address, email address, phone number, and account title. You may,
however, opt-out of this information sharing arrangement - see Financial Advisor Sharing Opt-Out in the
Other important information section below.

To limit our • Call 1-888-528-8460 - our menu will prompt you through your choices.
sharing • Online and mobile banking customers - sign on and from the My Profile or Profile menu, select Change Privacy
Preferences or Privacy Preferences.
Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this
notice. When you are no longer our customer, we can continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.

To limit direct To limit direct marketing

marketing • To limit our direct marketing to you by mail or telephone, call 1-888-528-8460 - our menu will prompt you through your
choices.
• Online and mobile banking customers - sign on and from the My Profile or Profile menu, select Change Privacy
Preferences or Privacy Preferences.
Please note: A Do Not Call election is effective for five years, or while you are an active consumer customer, if longer
than five years. The Do Not Mail election is effective for three years. You may continue to receive marketing information
in regular account mailings and statements, when you visit us online or at an ATM. You may also be contacted to service
your account or participate in surveys. If you have an assigned client manager or team, they may continue to contact you
to assist you in managing your portfolio or account relationship.
Questions? Call 1-800-TO-WELLS (1-800-869-3557) or go to wellsfargo.com/privacy-security.

Who we are
Who is providing Wells Fargo Advisors; Wells Fargo Clearing Services, LLC; or Wells Fargo Clearing Services, LLC, doing business as
this notice? Wells Fargo Advisors.

What we do
How does WFA To protect your personal information from unauthorized access and use, we use security measures that comply with
protect my federal law. These measures include computer safeguards and secured files and buildings. For more information visit
personal wellsfargo.com/privacy-security.
information?

557706 (Rev 26 - 06/22) Page 1 of 2

 What we do
How does WFA We collect your personal information, for example, when you:
collect my • open an account
personal • seek advice about your investments
information? • make deposits or withdrawals from your accounts
• enter into an investment advisory contract
• seek financial or tax advice
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can't I limit all Federal law gives you the right to limit only:
sharing? • sharing for affiliates' everyday business purposes - information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates 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.
What happens Your choices will apply individually unless you tell us otherwise. Any account holder may express a privacy preference
when I limit sharing on behalf of the other joint account holders.
for an account I
hold jointly with
someone else?

Definitions
Affiliates Companies related by common ownership or control. They can be financial and non-financial companies.
• Our affiliates include financial companies with Wells Fargo in their name such as Wells Fargo Bank, N.A.
Nonaffiliates Companies not related by common ownership or control. They can be financial and non-financial companies.
• WFA does not share with nonaffiliates so they can market to you.
Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
• WFA does not jointly market.

Other important information

Important Notice about Credit Reporting: We may report information about your account(s) to credit bureaus and/or consumer-reporting
agencies. Late payments, missed payments, or other defaults on your account(s) may be reflected in your credit report and/or consumer report.
Do Not Call Policy. This Privacy Policy constitutes Wells Fargo & Company's Do Not Call Policy under the Telephone Consumer Protection Act
for all consumers. Wells Fargo & Company maintains an internal Do Not Call preference list. Do Not Call requests will be honored within 30 days
and will be effective for at least five years from the date of request. No telemarketing calls will be made to residential or cellular phone numbers
that appear on the Wells Fargo & Company's Do Not Call list.
Nevada residents: We are providing you this notice pursuant to state law. You may be placed on Wells Fargo & Company's internal Do Not Call
List by following the directions in the To limit direct marketing section. For more information regarding our telemarketing practices, contact us at
1-800-869-3557; PrivacyCenter@wellsfargo.com, or Wells Fargo, P.O. Box 5110, Sioux Falls, SD 57117-5110. If you would like more
information regarding this Nevada law, contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington
St., Suite 3900, Las Vegas, NV 89101; 702-486-3132; AgInfo@ag.nv.gov.
State Law: We follow state law where state law provides you with additional privacy protections.
Financial Advisor Sharing Opt-Out: As explained during account opening, if your financial advisor's affiliation with Wells Fargo Advisors ends
and your financial advisor joins a securities broker-dealer not affiliated with Wells Fargo Advisors, you have authorized Wells Fargo Advisors to
share your name, address, email address, phone number, and account titles with your financial advisor, as a usual means for your financial
advisor to offer to continue to service and maintain your accounts. To withdraw your prior authorization, call 1-877-481-2766 or 704-499-6744.

Wells Fargo U.S. legal entities and businesses covered by this notice
Wells Fargo Advisors; Wells Fargo Clearing Services, LLC; or Wells Fargo Clearing Services, LLC, doing business as Wells Fargo Advisors.
Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC, Member SIPC, a registered broker-dealer and non-bank
affiliate of Wells Fargo & Company. (Wells Fargo)
The following legal entities and businesses are not covered by this notice and have separate privacy notices:
• Wells Fargo Bank, N.A.
• Wells Fargo Retail Services, a division of Wells Fargo Bank, N.A.
• Wells Fargo Investment Institute, Inc.
• Global Alternative Investments
• Wells Fargo Advisors Financial Network, LLC
• Any insurance company, insurance agency, or other company that has its own privacy notice or policy
• Businesses that have provided a separate privacy notice governing specified accounts or relationships

© 2022 Wells Fargo Clearing Services, LLC. All rights reserved.

557706 (Rev 26 - 06/22) Page 2 of 2
Wells Fargo Advisors U.S. Privacy Notice Rev. 1/2022

FACTS WHAT DOES WELLS FARGO ADVISORS (WFA) DO WITH YOUR PERSONAL INFORMATION?
Why? 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.

What? 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 employment information
• account balances and transaction history
• credit history and investment experience
How? 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 Wells Fargo Advisors
chooses to share; and whether you can limit this sharing.

Does WFA Can you limit this

Reasons we can share your personal information share? sharing?

For our everyday business purposes - such as to process your transactions, maintain your account(s), Yes No
respond to court orders and legal investigations, or report to credit bureaus
For our marketing purposes - with service providers we use to offer our products and services to you Yes No
(please see below to limit the ways in which we contact you)
For joint marketing with other financial companies No We don't share
For our affiliates' everyday business purposes - information about your transactions and experiences Yes No
For our affiliates' everyday business purposes - information about your creditworthiness Yes Yes
For our affiliates to market to you Yes Yes
For nonaffiliates to market to you No* We don't share
*If your financial advisor departs WFA and joins a non-affiliated securities broker-dealer with which WFA has
entered into an agreement regarding financial advisors changing firms, WFA may share with your financial
advisor certain limited contact information which will be used to solicit you to join the new firm. The only
information WFA will share is your name, address, email address, phone number, and account title. You may,
however, opt-out of this information sharing arrangement - see Financial Advisor Sharing Opt-Out in the
Other important information section below.

To limit our • Call 1-888-528-8460 - our menu will prompt you through your choices.
sharing • Online and mobile banking customers - sign on and from the My Profile or Profile menu, select Change Privacy
Preferences or Privacy Preferences.
Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this
notice. When you are no longer our customer, we can continue to share your information as described in this notice.
However, you can contact us at any time to limit our sharing.

To limit direct To limit direct marketing

marketing • To limit our direct marketing to you by mail or telephone, call 1-888-528-8460 - our menu will prompt you through your
choices.
• Online and mobile banking customers - sign on and from the My Profile or Profile menu, select Change Privacy
Preferences or Privacy Preferences.
Please note: A Do Not Call election is effective for five years, or while you are an active consumer customer, if longer
than five years. The Do Not Mail election is effective for three years. You may continue to receive marketing information
in regular account mailings and statements, when you visit us online or at an ATM. You may also be contacted to service
your account or participate in surveys. If you have an assigned client manager or team, they may continue to contact you
to assist you in managing your portfolio or account relationship.
Questions? Call 1-800-TO-WELLS (1-800-869-3557) or go to wellsfargo.com/privacy-security.

Who we are
Who is providing Wells Fargo Advisors; Wells Fargo Clearing Services, LLC; or Wells Fargo Clearing Services, LLC, doing business as
this notice? Wells Fargo Advisors.

What we do
How does WFA To protect your personal information from unauthorized access and use, we use security measures that comply with
protect my federal law. These measures include computer safeguards and secured files and buildings. For more information visit
personal wellsfargo.com/privacy-security.
information?

557706 (Rev 26 - 06/22)

586380 (Rev 38 - 09/22) Page 1 of 21
What we do
How does WFA We collect your personal information, for example, when you:
collect my • open an account
personal • seek advice about your investments
information? • make deposits or withdrawals from your accounts
• enter into an investment advisory contract
• seek financial or tax advice
We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can't I limit all Federal law gives you the right to limit only:
sharing? • sharing for affiliates' everyday business purposes - information about your creditworthiness
• affiliates from using your information to market to you
• sharing for nonaffiliates 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.
What happens Your choices will apply individually unless you tell us otherwise. Any account holder may express a privacy preference
when I limit sharing on behalf of the other joint account holders.
for an account I
hold jointly with
someone else?

Definitions
Affiliates Companies related by common ownership or control. They can be financial and non-financial companies.
• Our affiliates include financial companies with Wells Fargo in their name such as Wells Fargo Bank, N.A.
Nonaffiliates Companies not related by common ownership or control. They can be financial and non-financial companies.
• WFA does not share with nonaffiliates so they can market to you.
Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
• WFA does not jointly market.

Other important information

Important Notice about Credit Reporting: We may report information about your account(s) to credit bureaus and/or consumer-reporting
agencies. Late payments, missed payments, or other defaults on your account(s) may be reflected in your credit report and/or consumer report.
Do Not Call Policy. This Privacy Policy constitutes Wells Fargo & Company's Do Not Call Policy under the Telephone Consumer Protection Act
for all consumers. Wells Fargo & Company maintains an internal Do Not Call preference list. Do Not Call requests will be honored within 30 days
and will be effective for at least five years from the date of request. No telemarketing calls will be made to residential or cellular phone numbers
that appear on the Wells Fargo & Company's Do Not Call list.
Nevada residents: We are providing you this notice pursuant to state law. You may be placed on Wells Fargo & Company's internal Do Not Call
List by following the directions in the To limit direct marketing section. For more information regarding our telemarketing practices, contact us at
1-800-869-3557; PrivacyCenter@wellsfargo.com, or Wells Fargo, P.O. Box 5110, Sioux Falls, SD 57117-5110. If you would like more
information regarding this Nevada law, contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington
St., Suite 3900, Las Vegas, NV 89101; 702-486-3132; AgInfo@ag.nv.gov.
State Law: We follow state law where state law provides you with additional privacy protections.
Financial Advisor Sharing Opt-Out: As explained during account opening, if your financial advisor's affiliation with Wells Fargo Advisors ends
and your financial advisor joins a securities broker-dealer not affiliated with Wells Fargo Advisors, you have authorized Wells Fargo Advisors to
share your name, address, email address, phone number, and account titles with your financial advisor, as a usual means for your financial
advisor to offer to continue to service and maintain your accounts. To withdraw your prior authorization, call 1-877-481-2766 or 704-499-6744.

Wells Fargo U.S. legal entities and businesses covered by this notice
Wells Fargo Advisors; Wells Fargo Clearing Services, LLC; or Wells Fargo Clearing Services, LLC, doing business as Wells Fargo Advisors.
Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC, Member SIPC, a registered broker-dealer and non-bank
affiliate of Wells Fargo & Company. (Wells Fargo)
The following legal entities and businesses are not covered by this notice and have separate privacy notices:
• Wells Fargo Bank, N.A.
• Wells Fargo Retail Services, a division of Wells Fargo Bank, N.A.
• Wells Fargo Investment Institute, Inc.
• Global Alternative Investments
• Wells Fargo Advisors Financial Network, LLC
• Any insurance company, insurance agency, or other company that has its own privacy notice or policy
• Businesses that have provided a separate privacy notice governing specified accounts or relationships

557706 (Rev 26 - 06/22)

© 2022 Wells Fargo Clearing Services, LLC. All rights reserved.
586380 (Rev 38 - 09/22) Page 2 of 21
Account Disclosures

Today, a wide variety of mutual funds are A money market fund is an open-end mutual
1. REFERRALS TO available and many funds are increasingly fund that is required to invest in low-risk
AFFILIATES complex or specialized or employ
complicated investment strategies, such as
short-term securities, which may include
municipal securities. Money market funds are
We may refer you to one of our Affiliates for leverage and short selling. In addition, generally liquid due to the short-term nature
banking and lending products or services complex funds more commonly invest in of their underlying investments and are
including mortgages, home equity lines of alternative investments such as commodities, typically used by investors who have a low
credit, credit cards, wealth management, foreign currencies, and derivatives. risk tolerance. Investors interested in a
trusts, and deposit accounts. You are not conservative alternative for their discretionary
required to obtain banking or lending services It is important to have a complete money may find that money market mutual
from an Affiliate and you are free to shop understanding of the investment strategies funds may allow for preservation of capital,
around. WFA and your investment and underlying products to understand the liquidity and return on principal.
professional may receive a financial or other mutual fund's value to associated risks. For
benefit from a referral. We may provide a example, the level and type of risk associated On July 23, 2014, the Securities and
special cash or non-cash incentive to your with mutual funds may vary significantly from Exchange Commission adopted amendments
investment professional for referrals to an one fund to another. Complex funds in to the rules that govern money market funds.
Affiliate. These incentives, as well as financial particular are subject to a number of risks, These rules became effective on October 14,
or other benefits received to refer you to an including increased volatility and greater 2016. The amended rules are designed to
Affiliate, create a conflict of interest for both potential for loss, and are not suitable for all reduce the risk of investor runs on money
your investment professional and us. For investors. Before investing in any mutual market funds in times of financial crisis and
some banking products, such as mortgages, fund, you should read about these risks, increase the transparency of these funds to
you will receive additional disclosure which are explained in detail in each mutual investors.
information at or near the time of referral. fund's prospectus, and discuss your
Please read this information carefully. investment goals and objectives with your A key element of the reform is the
Financial Advisor. establishment of three categories of money
market funds: retail, government, and
2. A GUIDE TO INVESTING We have a responsibility to consider institutional. There are a variety of changes
IN MUTUAL FUNDS reasonably available alternatives in making a and distinctions within these categories,
recommendation. We do not need to evaluate based on the type of fund, including
What you should know before every possible alternative either within our restrictions on who can invest in retail money
products or outside the firm in making a market funds and the requirement that
you buy recommendation. We are not required to offer institutional prime (funds that invest in
Wells Fargo Advisors wants to ensure that the "best" or lowest cost product. While cost corporate debt) and municipal money market
you are investing in the mutual funds and the is a factor that we take into consideration in funds move from a stable $1 price per share
share classes that best suit your investment making a recommendation, it is not the only net asset value (NAV) to a floating NAV.
objectives, risk tolerance, time horizon and factor.
In addition, the reform includes provisions
diversification needs. This guide will help you You should consider factors such as the requiring the funds (excluding government
better understand the features and costs below prior to accepting a recommendation: funds) to impose liquidity fees and possibly
associated with the various share classes, as
suspend or limit share redemptions when a
well as how your Financial Advisor and Wells • The potential risks, rewards, and costs in fund's portfolio fails to meet certain liquidity
Fargo Advisors are compensated when you purchasing and in the future selling a thresholds. These new rules allow for
invest in mutual funds through Wells Fargo security. redemption fees of up to 2% and the
Advisors. It will also help you take advantage
• Your age, other investments, financial suspension of share redemptions for up to 10
of all available discounts as you work with
situation and needs, tax status, investment business days during a 90-day period if the
your Financial Advisor.
objectives, investment experience, fund's board determines it is in the fund's
As always, if you have any questions about investment time horizon, liquidity needs, best interests to do so. This must be promptly
your mutual fund investments, please contact and risk tolerance. and publicly disclosed.
your Financial Advisor. • The security's investment objectives, Differences between the three types
WHAT IS A MUTUAL FUND? characteristics (including any special or of money market funds
unusual features), liquidity, volatility, and
A "mutual fund" is a company that pools likely performance in a variety of market Retail money market funds must have
money from many investors and invests it in and economic conditions. policies and procedures reasonably designed
a single portfolio of securities that is to limit beneficial ownership to natural
professionally managed. The mutual fund • For complex products, you should persons, meaning individual investors. The
company owns the underlying investments, consider whether less complex or costly definition of natural person includes
and the individual investors own shares of the products achieve the same objectives. participants in certain tax-deferred accounts,
fund. such as defined contribution plans.
By accepting a recommendation, you Institutional investors currently in these funds
The fund manager is responsible for selecting acknowledge that you have considered the will be required to exchange their shares.
and diversifying the fund's investments to above factors to your satisfaction. These funds transact at a stable $1.00 NAV
meet the fund's investment objective while * Source: https://www.icifactbook.org/ and may be subject to the imposition of a
managing risk. Funds generally invest in a mandatory or discretionary liquidity fee and
variety of investments, including U.S. or TYPES OF MUTUAL FUNDS redemption gate during periods of extreme
international stocks, bonds, money market market stress if the fund's board determines it
instruments or in any combination. Money market mutual funds is in the fund's best interests to do so.
Since the first U.S. mutual fund appeared in Like all mutual funds, money market funds Government money market funds are
1924, investors have entrusted their savings are sold by prospectus. It is important to available to both retail and institutional
for homes, education, retirement, and other consult the prospectus when considering investors. These funds are required to invest
major financial goals to mutual funds. As of whether or not to invest in a fund. The at least 99.5% of their total assets in cash,
early 2019, over 8,000 mutual funds hold prospectus contains information on the fund's government securities, or cash. They trade at
about $18 trillion in assets for approximately investment objectives or goals, principal a stable $1.00 NAV and are not required but
half of all American households.* Wells Fargo strategies for achieving those goals, principal have the option to, voluntarily adopt the
Advisors offers over 300 different mutual fund risks of investing in the fund, fees, charges liquidity fee/redemption gate provisions if
families. and expenses, past performance, and other previously disclosed to investors.
important information you should know before
investing.

586380 (Rev 38 - 09/22) Page 3 of 21

Institutional prime and institutional municipal consistent with your overall investment Risk considerations
money market funds (tax-exempt funds) are objectives. • Municipal bond funds are subject to the
required to maintain a floating NAV for sales same risks as their underlying municipal
and redemptions based on the current market Risk considerations
securities. Economic issues may impact
value of the securities held in the fund. Share Target-date funds should not be selected the performance of the municipal bond
prices fluctuate depending on market based solely on age or retirement date. Be issuer. As a result, principal is at risk or
conditions and are rounded to the fourth sure to assess the fund details and make subject to fluctuation. For instance, if the
decimal place ($1.0000). These funds may sure that its objectives and holdings are underlying municipality defaults or the
have multiple intraday price times to consistent with your risk tolerance and security is downgraded, the value of your
accommodate same day settlement. And personal investment objectives. portfolio may also decrease.
these funds are subject to liquidity fees and
the temporary suspension of withdrawals. In • Target-date funds do not provide a • Some single-state municipal bond funds
addition, institutional money market funds no guaranteed return and do not guarantee may lack the diversification of a fund that
longer support certain account features, such protection of principal at any time including invests in multiple-state issues such as a
as check writing. its target date. multi-state or national fund.
Risk considerations • Target-date funds are subject to the risks • Municipal bond funds often hold securities
associated with the underlying funds in from outside their designated country or
• You could lose money by investing in a which they invest. These risks change
money market fund. state (including securities from U.S.
over time as the fund's asset allocation territories such as Puerto Rico).
• Although stable value money market funds strategy adjusts as it approaches its target
seek to preserve the value of your date. They may not meet their stated
investment objectives and goals, and may
High yield and floating rate mutual
investment at $1.00 per share, it cannot
guarantee it will do so. lose money. funds
High yield and floating rate mutual funds are
• Alternatively, because the share price of Fixed income mutual funds both fixed income funds that invest primarily
floating NAV money market funds will Fixed income funds, or bond funds, are a in below investment grade securities
fluctuate, when you sell your shares they type of mutual fund that primarily invests in a (sometimes called junk bonds).
may be worth more or less than what you specific type of bond, or a mix of bonds or
originally paid for them. investments such as government, municipal, The securities held within high yield and
convertible and zero-coupon bonds as well floating rate funds are often rated below
• The fund may impose a fee of up to 2% investment grade by one or more of the
upon the sale of your shares or may as mortgage-backed securities.
nationally recognized statistical rating
temporarily suspend your ability to sell organizations or may not be rated by a rating
Risk considerations
shares if the fund's liquidity falls below agency.
required minimums because of market • Bond funds can lose value especially in
conditions or other factors. periods of rising interest rates. The inverse These funds take on the risks of the
• An investment in a money market mutual relationship (associated with traditional underlying instruments held in the fund
fund is not insured or guaranteed by the bond prices and yields) also applies to portfolio. For instance, the "floating rate"
Federal Deposit Insurance Corporation or bond funds. When interest rates rise, the indicates that the interest rate tied to the
any other government agency. bond prices fall and correlated bond fund underlying instruments will rise and fall, or
values may drop as well. The opposite is float, with the variable rate changes and
• The fund sponsor has no legal obligation true as well; if interest rates and bond market conditions. These interest rates
to provide financial support to the fund, yields fall, then bond prices could rise. usually adjust every 30-90 days. Investors
and you should not expect that the should take interest rate spreads, credit
sponsor will provide financial support to • As a result, the underlying bonds held in a
quality, and collateral into account when
the fund at any time. bond fund are subject to credit, interest
considering the fund's portfolio.
rate, reinvestment, prepayment, and
• While Money Market Funds typically liquidity risks, which may be reflected in Risk considerations
maintain a stable Net Asset Value the bond funds net asset value (NAV).
("NAV"), some funds may choose to • High yield and floating rate funds are
convert from a Stable NAV to a floating • The fees and expenses of a mutual fund considered speculative and carry
NAV Money Market Fund. can erode the interest rate and net asset increased risks of price volatility,
value of a bond fund, which reduced the underlying issuer creditworthiness,
For more information, contact your Financial return to the investor. illiquidity and the possibility of default in
Advisor, or read A Guide to Investing in Cash • Bond funds do not have a fixed maturity the timely payment of interest and
Alternatives by Wells Fargo Advisors date. The lack of a fixed maturity date and principal, which may impact the value of
(www.wellsfargoadvisors.com/guides). potential investors' demands for your portfolio.
redemption are factors that may also have • These funds do not maintain a stable net
Target-date mutual funds a negative impact on the fund's NAV and asset value and should not be considered
A "target-date" mutual fund (also known as a share price. The net asset value of a bond cash alternative funds. You can lose
"life-cycle" or "age-based" fund) is designed fund may be affected by a number of money in these funds.
to provide a simplified investment strategy factors related to the underlying securities
through a single investment. The fund including, but not limited to, credit quality, For more information about individual high
manager focuses on a particular time horizon duration, liquidity, and security structure. yield bonds, please read A Guide to
in the future (such as 2020, 2030, or 2040) Investing in High Yield Bonds by Wells
and adjusts the underlying portfolio and asset Municipal bond funds Fargo Advisors
mix to manage the level of risk and the Municipal bond funds are fixed income funds (www.wellsfargoadvisors.com/guides).
volatility as the target date approaches. that invest primarily in tax-free municipal
securities and are subject to the For more information about floating rate
Target-date funds generally consist of a
creditworthiness of their issuers. Although securities, please read A Guide to Investing
blend or bundle of existing mutual funds. This
income from municipal securities is generally in Floating Rate Securities by Wells Fargo
"fund of funds" concept may provide greater free from federal taxes and state taxes (for Advisors
diversification, but it may do so at the cost of
residents of the issuing state), capital gains (www.wellsfargoadvisors.com/guides).
higher ongoing fees and expenses
and capital gains distributions, if any, will be
associated with the underlying investments.
subject to taxes. Income for some investors
Because each mutual fund manager's International Funds
may also be subject to the Federal
approach to investment strategy and risk will
Alternative Minimum Tax (AMT). You should Mutual funds may invest in foreign securities
differ, two different funds with the same
not buy a fixed income fund based solely on and currencies of developed, emerging
targeted date may have noticeably different
the yield. It is important to consider all risks market, and frontier market countries.
allocations and performance from each other.
and characteristics of a bond fund when
These funds should be reviewed on a
making your investment decisions.
periodic basis to ensure that they remain

586380 (Rev 38 - 09/22) Page 4 of 21

Risk considerations or using total return swaps and/or futures Alt fund strategies may be complex including
• International investments (equity and fixed contracts. The funds may be leveraged up hedging and leveraging through derivatives,
income) may be subject to increased risks to negative three-times (-3x). short selling, and "opportunistic" strategies
and could lose value as a result of that change with market conditions. Some Alt
Funds for sophisticated investors funds employ a single strategy, while others
political, financial, and economic events in
foreign countries. Nontraditional mutual funds are not may use multiple strategies within the same
appropriate for all investors. They are fund.
• Foreign investments typically have less designed for sophisticated investors who:
publicly available information than U.S. Alt funds are managed to a wide range of
investments, are subject to less stringent • Understand the risks associated with the investment objectives. In some cases, the
foreign securities regulations than use of leverage and other complex fund's primary objective may be to generate
domestic securities, and are influenced by strategies above-market returns. In other cases, a
different factors than in the U.S. • Understand the consequences associated fund's main goal may be to help investors
with daily leveraged investment results better manage risk with strategies designed
Complex mutual funds to smooth out volatility or offer greater
• Accept the risks and volatility associated diversification.
Some mutual funds employ complex and
with investing in complex mutual funds
specialized investment strategies. These Risk considerations
funds commonly invest in alternative • Intend to actively monitor and manage
investments such as commodities, foreign their investments on a daily basis • Alt funds are not appropriate for all
currencies, and derivatives, and may employ investors, and it's important to understand
a flexible approach to invest widely across Risk considerations the strategy of the fund you are
asset classes and use complicated and Although nontraditional mutual funds are purchasing.
aggressive investment strategies such as designed to correlate to the same underlying • Alt funds may have relatively higher
leveraging and short selling to manage their benchmark index as a traditional mutual fund, expense ratios when compared to
portfolios. nontraditional mutual funds' investment traditional funds. Please see the fund's
strategies are complex and present additional prospectus for details, as well as other
Risk considerations risks. Nontraditional mutual funds rebalance characteristics and potential risks.
• Complex funds are subject to increased on a daily or monthly basis, per their
respective investment objective, and their Costs of investing in mutual funds
volatility and greater potential for loss.
performance over periods of time beyond A fund's prospectus provides information
• The level and type of risk associated with their stated reset period can vary dramatically about a fund's objectives, risks, and other
complex mutual funds may vary from that investment objective. They typically characteristics, as well as the fee and
significantly from one fund to another. It is perform as daily or monthly trading vehicles charges you pay, including sales charges and
important to have a broad understanding and are not intended for investors seeking a annual operating expenses. Depending on
of the investment strategies and buy-and-hold strategy, particularly in volatile the share class you choose, charges can be
underlying products from which a complex markets. In addition: paid in a variety of ways.
mutual fund derives its value in order to
evaluate its risks. • Nontraditional mutual fund positions Sales charges
should be monitored closely and These charges provide compensation for the
Non-traditional mutual funds frequently. fund company, Wells Fargo Advisors and
Nontraditional mutual funds are mutual funds • The volatility of the benchmark index your Financial Advisor, who helps you select
that are designed to deliver a multiple of the underlying a nontraditional mutual fund funds to pursue your investment objectives.
return, or the inverse thereof, of a designated during the holding period is a variable that Most sales charges are either "front-
benchmark index, on a daily or monthly affects the actual return of the fund and end" (charged when you buy shares) or
basis. These funds use complex, derivatives high volatility may result in a significant "back-end" (charged when you sell). A back-
based investment strategies, and their loss of principal. end charge is also called a "contingent
performance over time can deviate deferred sales charge (CDSC)," because as
significantly from the stated daily or monthly • The use of leverage within a nontraditional you hold your shares for longer periods the
objective. Nontraditional mutual funds mutual fund will magnify the effect of charge is reduced or eliminated.
include: volatility, so that, for example, a 3x fund
will perform worse in a volatile market than Operating expenses
• Inverse mutual funds. Inverse mutual a 2x fund based on the same index. Many of the costs associated with running a
funds seek a return that is the opposite
• As a result of periodic rebalancing, the mutual fund are operating expenses - or,
(-1x) return of the performance of an
return of leveraged or inverse fund with a simply put - the cost of doing business.
underlying benchmark index, on a daily (or
daily objective over periods longer than a Operating expenses are not paid directly as a
monthly) basis. This means that an
single day is unlikely to correlate to the fee, but they are deducted from the fund's
inverse mutual fund seeks to provide a 1%
return of the underlying benchmark index. assets, so they reduce investment returns.
gain on return for each 1% loss in the
This effect is pronounced in volatile Operating expenses include management
fund's benchmark index on a daily (or
markets. fees, 12b-1 fees,* (for marketing and
monthly) basis. Conversely, if the distribution expenses, which may include
benchmark index goes up 1% on a given
Given the complexity of these investment compensating Financial Advisors or other
day, the fund's loss, in theory, would be
products and the risks associated with them, investment professionals), shareholder
1% that day.
nontraditional mutual funds may not be mailings, and other expenses.
• Leveraged mutual funds. Leveraged appropriate for certain clients or investment
mutual funds seek a return that is a It is important to note that, generally, non-
portfolios. traditional mutual funds incur higher overall
multiple of the performance of an
underlying benchmark index, on a daily (or Alternative mutual funds expenses due to periodic rebalancing and the
monthly) basis, usually by using a use of complex investment strategies. This is
Alternative mutual funds (Alt funds) are also true for Target Date Funds and Asset
combination of individual securities, designed to seek the fund's objectives
futures and total return swaps. A Allocation Funds that invest in underlying
through nontraditional trading strategies and mutual funds of the fund company. The
leveraged mutual fund attempts to provide investments, such as global real estate,
a return measured by a positive multiple, fund's prospectus will note the fund's
commodities, leveraged loans, start-up expense ratio (a measure of what it costs an
up to three-times (3x) the performance of companies, and unlisted securities that offer
the index on a daily (or monthly) basis. investment company to operate a mutual
exposure beyond traditional stocks, bonds, fund, expressed as a percentage of the
• Leveraged inverse mutual funds. and cash. To gain exposure to commodities, fund's net assets).
Leveraged inverse mutual funds, or "short" a fund may utilize an offshore subsidiary that
funds, seek to deliver the opposite of the is wholly-owned by the fund. A change in tax * The fund company takes 12b-1 fees out of
return of an underlying benchmark index, law or regulation could adversely affect the the fund's assets each year for marketing and
by a multiple of greater than -1x, on a daily way the fund is taxed, operated, and distribution expenses, which may include
(or monthly) basis, usually by short selling managed. compensating Financial Advisors or other
investment professionals.

586380 (Rev 38 - 09/22) Page 5 of 21

Redemption fees including where lower-cost share classes are portfolio. When taking into consideration
Redemption fees, which discourage frequent made available. An investor who holds a the total costs and expenses of C shares,
trading in mutual funds and to offset the less-expensive share class of a fund will pay investors should think carefully about
associated trade costs, may be charged lower fees over time and earn higher whether C shares are an appropriate
when shareholders redeem their mutual fund investment returns - than an investor who investment class for their investment
shares before a specified period defined by holds a more expensive share class of the goals, especially for investors intending to
the mutual fund company These fees are same fund. hold the C Shares for a longer period of
paid directly to the mutual fund company and time. Once again, Wells Fargo Advisors
• Class A shares (sometimes called "A has set limits to help ensure that the best
not to the Financial Advisor and are charged shares") typically charge a front-end sales
in addition to the initial sales charge paid. interest of clients is served, regardless of
charge (a fee charged when you first buy a the purchase size.
Because each fund's rules vary, be sure to mutual fund) that is deducted from your
check the mutual fund's prospectus for the initial investment. Operating expenses of • Class I shares are an institutional share
specific redemption period and schedule of the fund are generally lower for A shares class that is typically sold without a sales
fees. than for B or C shares. Be aware that most charge and with lower annual costs and
funds offer "breakpoint discounts" on the management expenses than traditional
Share classes share classes (like A, B, and C shares).
front-end sales charge for large
Typically, a mutual fund offers more than one investments, so as the size of your total Because I shares generally do not feature
"class" of its shares to investors. Each class investment within a fund family increases, a CDSC for the sale of your shares, they
represents a proportionate amount of the sales charge may decrease. have lower costs and expenses and are
ownership in the mutual fund's portfolio. typically offered at a much higher
Depending on the class you choose, each Also, most domestic mutual fund families minimum investment amount than class A,
share class will charge different fees and allow investors to aggregate holdings in B, or C shares.
expenses, which can affect the return of your related accounts to reach a breakpoint
investment over time. Although there are (and receive a discount). This is called • No-load shares do not carry either front-
many different classes, the most common are "rights of accumulation (ROA)." Those or back-end sales charges; however, they
"Class A," "Class B," and "Class C" while breakpoints typically occur at $25,000, do impose ongoing fees and expenses. If
advisory accounts typically utilize "Class I" $50,000, $100,000, $250,000, $500,000, you purchase or sell no-load funds through
and "No Load" share classes. and $1 million but may vary with the fund. a brokerage account, you may pay a
transaction fee to Wells Fargo Advisors to
Not all mutual funds or their share classes Finally, most fund families permit investors cover trade costs (with the mutual fund
are available for purchase at Wells Fargo to sign a "letter of intent (LOI)" to invest a company on your behalf), and sending
Advisors or within certain account types. We certain amount in the fund over a certain trade confirmations and statements. Keep
may allow you to hold mutual fund share period of time, entitling them to a in mind that other fees and expenses
classes in your account which may have a breakpoint discount at lower initial levels of apply to ongoing investment in mutual
lower total expense ratio than the mutual fund investment. Each fund's rules about ROAs fund shares and that these are described
share class allowed for purchase here. If you and LOIs differ, so be sure to speak with in the fee table in the prospectus.
hold the lower expense ratio share class in a your Financial Advisor before investing.
particular mutual fund that is not available for • Class B shares typically have no front- Which share class is right for you?
purchase here you will not be allowed to add end sales charge and impose higher
to that position or make new purchases. Before choosing a share class, consider the
annual operating expenses than A shares.
Similarly, you will not be allowed to convert following questions:
However, Class B shares are not "no-load"
the lower expense ratio share class to a more funds because B shares normally impose • How long do I plan to hold the fund?
expensive share class we make available. a CDSC, which you pay if you sell your
Other share classes in the same mutual fund shares within a certain number of years. • How much money do I intend to invest?
may or may not be available for new The CDSC generally gets smaller each • Will I be purchasing more shares in the
purchases. year and is usually eliminated after the future?
seventh or eighth year. At that point, some
Depending on the type of share class you B shares may convert to A shares. • What expenses will I pay for each class?
wish to hold in your account, we may be
Investors may find B shares to be most • Do I qualify for any sales charge
compensated for any shares transferred here
appropriate when investing modest discounts?
even if you are not permitted to add to the
position or make new purchases. For more amounts for longer periods. However, if Talking with your Financial Advisor about
information about how we are compensated, the B shares do not convert to A shares these questions will help you make an
please see the section below regarding and the operating expenses remain at a informed decision when determining which
“Additional compensation received by Wells higher level, B shares may not be the most share class(es) match your needs, resources,
Fargo Advisors from mutual fund companies.” economical choice over longer holding and time horizon.
periods. Many fund companies permit
Prior to transferring mutual fund investments investors to aggregate B share and C Expense Fund Analyzer
to us you should consider the fees you may share positions with new A share To compare expenses by share class, you
have already paid for the mutual fund and purchases to obtain breakpoints. As a best may want to use the Fund Analyzer tool
whether or not you will be able purchase practice, Wells Fargo Advisors has set provided by the Financial Industry Regulatory
additional shares of the mutual fund. Please limits to help ensure that the best interest Authority (FINRA) at
ask your financial professional if investments of clients is served whatever the purchase
you wish to hold here are permitted before https://www.finra.org/investors/tools-and-
size may be.
transferring them. If you are seeking to calculators.
transfer a mutual fund share class that is • Class C shares do not have a front-end
sales charge and generally impose a lower This fund and expense calculator is not
ineligible for purchase here into an account available for offshore funds.
that is enrolled in an advisory program, the CDSC than B shares, often 1% for 1 year.
advisory program documents should be Like B shares, C shares normally impose
higher annual operating expenses than A
Advisory Fee-Based Accounts
reviewed prior to making the transfer in order At Wells Fargo Advisors, investors can also
to determine whether that particular share shares, but depending on the fund, C
shares may convert to A shares. Please buy mutual funds through investment
class can be held here. advisory fee-based ("wrap fee") programs for
see the prospectus for more information.
Other funds and share classes may have Investors who want flexibility and who their discretionary and non-discretionary
different charges, fees, and expenses, which have a shorter investment time horizon accounts. Instead of paying a sales charge or
may be lower than the charges, fees, and may find that C shares best meet their commission on each transaction, you pay an
expenses of the funds and share classes we needs; however, not all fund families offer annual fee based on a percentage of the
make available. These funds and share C shares. account's value, which is billed quarterly.
classes are available through other broker- Annual fund operating expenses still apply.
C shares are generally most appropriate
dealers and financial intermediaries, including for investors who want more flexibility in These programs offer a variety of share
our affiliates, and the Funds directly, constructing and managing a diversified classes (institutional, advisory, no-load

586380 (Rev 38 - 09/22) Page 6 of 21

shares or A shares) and waive the front-end • Be subject to a new redemption period (if share classes (i.e., Class A share or
sales charge. I and Advisory share classes you switch into share classes that have equivalents) for qualified retirement plans
are commonly offered in Wells Fargo CDSCs, such as B and C shares) (QRPs such as 401(k)s, 403(b)s, or profit-
Advisors' advisory programs. sharing and defined benefit plans), SIMPLEs,
In these instances, you will receive a mutual SEPs, and charities (including foundations
These programs and accounts also provide fund switch letter, which discloses information and nonprofits) and allow the trades to be
additional benefits and features that may not regarding your switch, including the potential placed at NAV subject to specific eligibility
be available in a traditional Wells Fargo availability of an exchange within your requirements as disclosed in the prospectus.
Advisors' brokerage account. Therefore, the existing open-end mutual fund family, and the Fund families and, sometimes, individual
total cost of purchasing and holding a fund in possibility of additional costs and expenses. mutual funds within a fund family have their
these programs may be more than in a own unique requirements for sales charge
traditional brokerage account. Be aware that tax consequences related to
your sale, redemption, or exchange of mutual waivers including minimum plan asset
Advisory-based programs are generally not fund shares, could result. For questions amounts, number of eligible employees or
designed for excessively traded or inactive regarding tax consequences, consult your tax plan participants. In some cases, the
accounts and may not be suitable for all advisor prior to making any such investment prospectus will give us discretion concerning
investors. decision. whether to allow a given sales charge waiver.
Review the prospectus and contact your
As discussed under "Additional Additional considerations when Financial Advisor for more information.
Compensation Received by Wells Fargo purchasing mutual funds
Advisors from Mutual Fund Companies," RISKS
WFA receives additional compensation from How you invest in mutual funds affects your
costs. For example: Here is a summary of risks to
mutual fund families for various services,
including training and education support, consider as you play your
• If you open and maintain your retirement
revenue sharing, and networking and account directly with a mutual fund
investments in mutual funds.
omnibus platform services. For additional company, you may qualify for benefits, • The fund may hold securities even though
information related to your advisory program, such as net asset value (NAV) privileges, their market value and dividend yields
see the program's ADV form. ROA and breakpoint discounts (described have changed. This may be true even
above). though the funds are generally actively
WellsTrade ® Self-Directed Brokerage managed (which means managers may
Accounts • However, if you open and maintain your purchase or sell securities in the fund
retirement account with Wells Fargo portfolio in an attempt to take advantage of
Investors with a WellsTrade account Advisors, you may forfeit your right to
independently choose and manage their changing market conditions).
these benefits and privileges. As a result,
mutual fund investments. Generally, your costs associated with the retirement • A mutual fund may carry the same
WellsTrade offers no-load mutual funds plan and mutual fund purchases may be investment risk as the securities within the
(some fund families may use Class A shares greater if you invest through our firm. fund. Securities in a fund portfolio may
without a sales charge). WellsTrade depreciate, and the fund may not achieve
investors, may buy and sell mutual funds • From time to time, fund families may its intended objective. In addition, each
online or through an Investment Professional. institute fee waivers for certain funds and/ mutual fund is subject to specific risks that
or share classes. Such waivers are vary depending on the fund's investment
As a WellsTrade investor, you may be voluntary arrangements to lower
assessed a no-load transaction fee on objectives and portfolio composition.
shareholder fees, which directly increase
various funds when you buy and sell no-load shareholder returns. Similarly, fund • A mutual fund that invests in foreign,
mutual funds. WellsTrade Investment families may decide to discontinue any including emerging and frontier markets,
Professionals, should you use one for a voluntary fee waiver, usually at any time have certain risks not associated with
transaction, do not receive compensation and without any advance notice that would domestic investments, such as currency
from the transaction fee. All Mutual fund in turn raise shareholder fees and reduce fluctuation, political and economic
shareholders incur annual fund operating shareholder returns. For additional instability, and different accounting
expenses, as discussed in the prospectus. information for a particular fund, please standards, which may result in greater
refer to the fund's prospectus. share price volatility. These risks are
Depending on the fund you select, Wells Shareholders should also review the heightened in frontier and emerging
Fargo Advisors may receive other forms of fund's website and other public markets.
compensation from mutual fund companies disclosures to access information on when
and their complexes. Please see the • Non-traditional mutual funds are complex
waivers, if any, are in place and/or products, and are subject to a number of
"Additional compensation received by Wells discontinued as reflected in a fund's most
Fargo Advisors from mutual fund companies" additional risks beyond those of traditional
recently updated yield. mutual funds and other risks discussed in
section.
Other fees this guide. Consequently, these funds
Mutual fund switches should only be purchased by sophisticated
You will be assessed a transaction fee when investors who understand the speculative
As your objectives change, you can switch you buy and sell load or no-load mutual funds
among the mutual funds in the mutual fund nature of these investments in volatile
through Wells Fargo Advisors and a separate markets.
family whose objectives most closely meet accommodation fee (for no-load funds
your needs, without incurring an additional purchases only). This fee does not apply to • Periodic rebalancing may increase or
sales charge. Staying within the same mutual eligible trades in advisory program accounts. decrease your exposure in response to
fund family may be preferable, because Keep in mind that mutual funds offered by the day's gains or losses. Some funds are
switching from one mutual fund family to Wells Fargo Advisors may be purchased in not intended to be held long term and
another may involve additional costs or fees. an advisory account without incurring a some non-traditional mutual funds may be
However, when the original mutual fund transaction fee or by purchasing directly thinly traded, which could impact your
family does not offer the type of investment through the mutual fund company. Your ability to quickly sell shares.
product you are interested in, it may be Financial Advisor does not receive • There is additional risk in non-traditional
appropriate to switch to a mutual fund in compensation from the transaction fee or mutual funds because of total return swap
another mutual fund family or another type of accommodation fee. agreements with different counterparties.
investment product (such as a variable Feel free to ask your Financial Advisor how If the counterparty becomes unable to
annuity or unit investment trust). he or she will be compensated for any mutual deliver its share of the contract, it will
fund transaction. default on the swap, which will negatively
If you choose to switch to another fund family affect the value of the non-traditional
(or investment type) and your account is mutual fund.
commission based, you will most likely:
Sales charge reductions for specific
types of accounts • Mutual funds that invest using alternative
• Incur a sales charge on the new strategies are more complex investment
Certain mutual fund companies waive sales
investment vehicles, which generally have higher
charges on purchases of front-end loaded

586380 (Rev 38 - 09/22) Page 7 of 21

 costs and substantial risks. They tend to HOW YOUR FINANCIAL ADVISOR paid by the fund complexes, not related to
be more volatile and present an increased individual transactions, for the ongoing
risk of investment loss. Compared with AND WELLS FARGO ADVISORS account maintenance, marketing support,
broad, long-only traditional asset class ARE COMPENSATED ON educational and training services performed
mutual funds, alternative mutual funds MUTUAL FUNDS by Wells Fargo Advisors in support of mutual
may employ more complex strategies, fund sales. This "non-commission"
investments, and portfolio structures. As a Wells Fargo Advisors and your Financial compensation received by Wells Fargo
result, some of these strategies may Advisor receive payments depending on the Advisors from fund complexes can be broken
expose investors to additional risks, type of fund (equity or fixed income), amount down into six general categories:
including but not limited to the following: invested, and share class that you select.
short selling, leverage risk, counterparty • Networking and omnibus platform services
risk, liquidity risk, commodity price • Wells Fargo Advisors are paid by the fund compensation
volatility risk, and/or managed futures roll family from the fees you pay. Part of that
payment then goes to your Financial • Revenue sharing
yield risk.
Advisor. • Training and education support
• Typically, mutual funds are able to satisfy
shareholder redemptions in cash. • For most purchases, a Financial Advisor's • Other compensation for general services
Although unusual, securities regulations compensation is based on a compensation provided to funds
permit mutual funds to redeem with formula applied (for A shares) to the front-
end sales charge described in the fund's • Data Agreements
securities-in-kind, and many mutual funds
disclose this redemption feature in their prospectus, or (for B and C shares) to the This additional cash compensation may
prospectuses. The disposal of in-kind selling fee (known as a "sales influence the selection of mutual funds that
securities may be subject to brokerage concession"), which is set and paid by the Wells Fargo Advisors and Firm associates
costs and, until sold, remain subject to fund family. make available for recommendation. Wells
market and liquidity risk, including the risk • Financial Advisors receive ongoing Fargo Advisors reserves the right to restrict
that such securities are or become difficult payments (known as "residuals" or "trails") the mutual fund companies that we offer to
to sell. on mutual fund shares, as set by the fund clients based on payment of additional cash
family and generally (except in the compensation.
Please refer to each fund's prospectus for advisory programs).
additional details. Please note that these compensation
• In certain fee-based accounts, Financial arrangements are described in the
INVESTOR CHARACTERISTICS Advisors' compensation is based on a prospectus and the Statement of Additional
percentage of the assets in the account, Information (SAI), which is a supplementary
Selecting the appropriate program and rather than on concessions or trails, as document to the prospectus, for each mutual
mutual funds for your investment objectives mentioned above fund offered by Wells Fargo Advisors. We
involves many factors, such as fund included this section in this guide to provide
strategies, fund performance history, risks, The compensation formula to determine the you with enhanced disclosure about the
investment time horizon, fees and expenses, amount of payment to your Financial Advisor compensation arrangements between Wells
and portability. To fully evaluate your options, is the same for all mutual funds. However, Fargo Advisors and mutual fund companies,
you should review any program's disclosure some funds may carry higher sales charges in particular, as well as any associated
document and the fund's share classes, as than others, which may create an incentive potential conflicts of interest.
detailed in the fund prospectus. for Financial Advisors to sell such funds.
Networking and omnibus platform
In addition, be aware that certain mutual Offshore mutual funds also normally carry
funds may not be transferable from one asset-based service fees. These service fees service fees
investment firm to another. As a result, if you are assessed by the mutual fund company These fees are designed to compensate
or your Financial Advisor change investment and paid to Wells Fargo Advisors, which may Wells Fargo Advisors for providing varying
firms, you may need to liquidate these pass them to your Financial Advisor as part degrees of customer account and
products, which may incur additional fees or of their compensation. These fees vary by administrative services for those Wells Fargo
tax consequences. In some instances, it may fund company, fund and share class, and can Advisors' customer accounts holding mutual
be prudent to leave these mutual funds at the be as low as 0.25% or as high as 1.5% funds. In recent years, fund companies have
previous firm rather than transfer them. annually. For more information, please read outsourced many of these operations
the prospectus carefully. functions to broker-dealers such as Wells
Remember, you are not required to sell such Fargo Advisors. The following are examples
mutual funds when you or your Financial Wells Fargo Advisors, which is a non-bank of networking and omnibus platform services:
Advisor changes firms. You can open an affiliate of Wells Fargo & Company, may the processing of purchases, redemptions
account with the new firm and transfer only enter into certain direct or indirect and exchanges; check processing; dividend
the mutual funds you choose. You are not compensation arrangements with other Wells reinvestments; preparation and mailing of
required that you move everything in your Fargo & Company affiliates. For example, consolidated account statements; delivery of
previous account or liquidate mutual funds Wells Fargo Advisors and its affiliates fund proxies and shareholder materials; tax
that are not transferable. typically receive compensation or credit in reporting; maintaining ownership records;
connection with the referral of certain and other sub accounting and record-keeping
Consult with your Financial Advisor to make business among Wells Fargo & Company services. Wells Fargo Advisors is responsible
the most appropriate decision for your subsidiaries, including the sale of mutual for all its costs associated with networking
financial situation. funds. and omnibus services we perform - including
Offshore Mutual Funds but not limited to technology and personnel.
Wells Fargo & Company, one of the largest Wells Fargo Advisors receives networking
Certain mutual funds are domiciled and financial holding companies in the United and omnibus platform service fees from
operated outside of the United States and are States, provides a wide range of financial mutual fund companies available in both
only available to people or entities that do not services to various mutual fund companies transaction-based and/or advisory program
qualify as "U.S. persons" under Reg S of the through its subsidiaries and affiliates, accounts.
Securities Act of 1933. These funds are including Wells Fargo Advisors.
called "offshore" mutual funds and, although • The compensation paid for networking and
they are not registered as securities in the ADDITIONAL COMPENSATION omnibus platform services is negotiated
United States, they function similarly to U.S. RECEIVED BY WELLS FARGO separately with each fund company and
mutual funds in terms of structure, the amount varies depending on the fund
investments, operations, risks, and costs. ADVISORS FROM MUTUAL FUND company and each individual fund.
COMPANIES • If a client owns multiple funds in one fund
In addition to the transaction-based family, Wells Fargo Advisors generally
commissions received by Wells Fargo receives networking and omnibus platform
Advisors and your Financial Advisor, Wells services compensation for each individual
Fargo Advisors may receive compensation fund.

586380 (Rev 38 - 09/22) Page 8 of 21

 • Wells Fargo Advisors may receive earned from services provided to the fund. In addition to the transaction-based
networking compensation based on a compensation received by your Financial
• Wells Fargo Advisors receives revenue
dollar amount per year, per client account Advisor and broker-dealer, for clients whose
sharing payments from mutual fund
with an individual fund or based on a broker-dealers clear and execute through
companies available in both transaction-
percentage of assets in a fund. Networking WFCS, WFCS may receive compensation
based and/or investment advisory
compensation is paid at a rate up to $12 paid by mutual fund companies and/or their
programs. Fund complexes have different
per year, per client account or at a rate of affiliates, not related to individual
criteria for determining this compensation.
up to 12 basis points on assets. transactions, for the ongoing account
Fund complexes may make payments
maintenance, marketing support, educational
• Compensation paid to Wells Fargo based on aggregate assets, a percentage
and training services in support of mutual
Advisors for omnibus platform services is of new sales, based on a complex's
fund sales conducted by your broker-dealer.
generally higher than networking determination of the scope of the
compensation because Wells Fargo relationship, or a combination of such Training and education
Advisors is required to perform a more criteria. The percentage amounts are
extensive array of services to clients and typically established in terms of basis compensation
the fund for omnibus accounts. points, which are equal to one one- Wells Fargo Advisors offers multiple ways for
hundredth of 1%. For example, if Wells mutual fund families to provide training and
We or our service providers typically collect Fargo Advisors receives 10 basis points in education to our Financial Advisors in local
from mutual funds in which you invest, revenue sharing for a given fund, it would branch offices or in larger group settings,
compensation for recordkeeping, receive $10 for each $10,000 of total including at the national level.
subaccounting, shareholder communications, assets in client accounts in the fund.
administrative, and other similar services we • Certain mutual fund families have agreed
provide to a fund for your benefit. In addition, Most mutual fund revenue sharing to dedicate resources and funding to
we generally collect other asset-based fees agreements are based on the greater of a provide this training and education at our
for the execution of fund share purchases, or basis point calculation on assets under nationally-organized events. This
the performance of clearance, settlement, management (AUM) or a minimum annual commitment could lead our Financial
custodial or other ancillary functions. We or fee expressed in a flat dollar amount. Since Advisors to focus on the mutual funds
our service providers collect such fees basis point calculations are based on AUM, offered from these mutual fund families
directly or indirectly from some or all of the this compensation to WFA fluctuates based versus the mutual funds offered by
mutual funds in which you invest. When on client holdings and market movement. families which are not represented during
providing services, Wells Fargo Advisors these training and education support
Revenue sharing arrangements vary across sessions.
does not pay any portion of these fees to its
fund families and different revenue sharing
FAs. The compensation paid for networking • Wells Fargo Advisors selects the mutual
rates may vary within a particular fund family.
and omnibus platform services, if any, is fund families that participate in the training
Fund complexes pay us revenue sharing or
negotiated separately with each fund and education events based on a variety
omnibus fees at a minimum rate for all money
company, and the amount varies depending of qualitative and quantitative criteria and
market mutual funds purchased. Wells Fargo
on the fund company and share class of each may provide supplemental sales and
Advisors receives different revenue sharing
individual fund. Fund complexes pay us Financial data to these firms. The subset
rates from each fund family, and may receive
revenue sharing or omnibus fees at a of mutual fund families that offer this
different revenue sharing rates for certain
minimum rate for all money market mutual support and participate in nationally-
funds within a particular fund family.
funds purchased. In addition, not all mutual organized training and education events
funds pay network and omnibus platform • Fund companies pay Wells Fargo may change periodically. The firms are
service fees, as a result we have an incentive Advisors revenue sharing compensation at identified on the last pages of the guide.
to include funds on our platform and an annual rate of up to 20 basis points on
recommend funds that pay networking and aggregate client assets (on a $10,000 • Mutual fund companies may also provide
omnibus platform service fees. client position, 20 basis points equals $20 compensation to offset or reimburse Wells
per year). Fargo Advisors for costs incurred in
Wells Fargo Advisors may receive omnibus conducting comprehensive training and
platform compensation based on a dollar • However, certain funds may pay Wells educational meetings for its Financial
amount per year, per client account with an Fargo Advisors a negotiated, fixed annual Advisors. These meetings or events are
individual fund or based on a percentage of amount for revenue sharing, regardless of held to teach Financial Advisors about the
assets in a fund. Omnibus compensation is the amount of assets held in client product characteristics, sales materials,
paid at a rate up to $25 per year, per client accounts or in new sales to clients. suitability, customer support services and
account or at a rate of up to 35 basis points • In addition to receiving revenue in successful sales techniques as they relate
on assets as agreed upon by the fund connection with the sale of mutual funds, to various mutual funds.
company and Wells Fargo Advisors. Wells Fargo Advisors receives revenue • Separately, mutual fund companies may
Depending on asset levels, basis point sharing in connection with the sale of host Financial Advisors for education and
pricing may result in higher or lower offshore funds, variable annuities and unit conferences at the fund company
compensation than a per position fee. investment trusts. headquarters, regional office or other
location. Likewise, occasionally, product
For example, $10,000 held in a given fund, Revenue sharing fees are usually paid as a
sponsors will reimburse Wells Fargo
might incur a per position fee up to $25 or a percentage of our aggregate value of Client
Advisors for expenses incurred by
basis point fee up to $35. These fees are assets invested in the funds. Revenue
individual branch offices in connection with
indirectly borne by the fund client, in that we sharing rates can differ depending on the
conducting training and educational
do not bill or collect these fees from clients. fund family, and in some cases we receive
meetings, conferences, or seminars for
Specific fund fees are disclosed in the fund different revenue sharing rates for certain
Financial Advisors and customers. Also,
prospectus and included in its expense ratio. funds and share classes within a particular
Financial Advisors may receive
fund family. In addition, not all mutual funds
Revenue Sharing promotional items, meals or entertainment,
pay revenue sharing, as a result we have an
or other non-cash compensation from
Revenue sharing is paid by a mutual fund's incentive to include funds on our platform and
product sponsors.
investment advisor, distributor, or other fund recommend funds that pay revenue sharing
affiliate to Wells Fargo Advisors for providing and/or pay a higher rate. Although training and education
continuing due diligence, training, operations compensation is not related to individual
and systems support, and marketing to Revenue sharing from offshore fund
transactions or assets held in client accounts,
Financial Advisors and clients with respect to complexes, which is generally structured
it is important to understand that, due to the
mutual fund companies and their funds. differently than domestic fund family
total number of product sponsors whose
complexes, is at annual rates of up to 55
• The fees are paid from the mutual fund products are offered by Wells Fargo
basis points on aggregate client assets (on a
affiliates or distributor's revenues and Advisors, it is not possible for all mutual fund
$10,000 client position, 55 basis points
profits, not from fund assets. However, companies to participate in a single meeting
equals $55 per year).
fund affiliates or distributor revenues or or event. Consequently, those product
profits may in part be derived from fees sponsors that do participate in training or

586380 (Rev 38 - 09/22) Page 9 of 21

educational meetings, seminars, or other • Require the mutual fund distributor or affiliates, such as mutual fund companies,
events gain an opportunity to build advisor to directly compensate Wells insurance carriers or money managers.
relationships with Financial Advisors; these Fargo Advisors for revenue sharing by Therefore, Financial Advisors and other
relationships could lead to additional sales of wire transfer or check, and prohibit funds associates have financial incentives to
that particular fund company's products. and their portfolio managers from directing recommend the programs and services
investment portfolio trades to Wells Fargo included in these firm-sponsored incentive
Additional compensation for general Advisors as "indirect" compensation for programs rather than other available products
services provided to funds revenue sharing. and services offered by Wells Fargo
Fund companies compensate Wells Fargo Advisors.
• Require reimbursement payments for
Advisors and its affiliates for certain business general educational and training expenses
services that Wells Fargo Advisors provides and for expenses associated with
AFFILIATE RELATIONSHIPS
to the funds in connection with their day-to- conducting individual branch office WITH MUTUAL FUND
day operation. The range of services that training, and educational activities to be COMPANIES
Wells Fargo Advisors and its affiliates provide recorded and approved.
to these investment advisors includes Wells Fargo & Company, one of the largest
investment banking, research, and trading. • Limit the annual dollar value of gifts or financial holding companies in the United
Wells Fargo Advisors also has a dedicated other non-cash items that mutual fund States, provides a wide range of financial
institutional sales force that specializes in companies and their representatives can services to various mutual fund companies
facilitating trading for institutional investors, provide to Financial Advisors. through its subsidiaries and affiliates,
which may include portfolio managers of including Wells Fargo Advisors. These
To help increase transparency concerning relationships provide financial and other
mutual funds that are sold by Wells Fargo these compensation relationships, you will
Advisors. Wells Fargo Advisors is benefits to Wells Fargo & Company as well
find a list of all the fund families that pay as Wells Fargo Advisors and other
compensated for the services provided in Wells Fargo Advisors networking, omnibus,
connection with these relationships, and the subsidiaries and affiliates.
platform services and/or revenue sharing
compensation received may vary between compensation in a table on the last pages of During the course of annual business
funds and between advisors. this guide. planning, business with our affiliates is
Data Agreements included in establishing Wells Fargo
In addition to those funds listed in the table, it Advisors' sales goals. However, our Financial
Wells Fargo Advisors works with various is important for you to understand that almost Advisors are instructed to make their
mutual fund families to provide aggregated every fund that is sold by Wells Fargo recommendations independent of any such
sales data. Data Agreements are paid by Advisors provides some degree of goals and based solely on the clients'
mutual fund complexes either under a 12b-1 educational, training or other noncash objectives and needs.
Plan, or as a revenue sharing arrangement in compensation to Wells Fargo Advisors and
which the payment is from a fund affiliate but its Financial Advisors. For example, if you Additionally, within the division that operates
not from fund assets. Payments range from attend training or educational meetings with in Wells Fargo branches and some Wells
$450,000 to $650,000. These fund complex your Financial Advisor and a representative Fargo Advisors branches, Financial Advisors
payments are paid to and retained by Wells of a mutual fund is in attendance, you should can assist you with your mutual fund
Fargo Advisors and the broker-dealer assume that the mutual fund has paid or investment needs.
entities, and are not directly shared with reimbursed Wells Fargo Advisors for part of
Financial Advisors. the total costs of the meeting or event. A licensed banker is a Wells Fargo Bank
associate who is registered with Wells Fargo
POTENTIAL CONFLICTS OF Wells Fargo Advisors offers a wide variety of Advisors.
fund families for our Financial Advisors to sell
INTEREST ASSOCIATED WITH or recommend, including funds that do not Licensed bankers may also refer you to a
ADDITIONAL COMPENSATION compensate Wells Fargo Advisors for any or Financial Advisor. In these instances, both
all of the services above. The payment of the Financial Advisor and the licensed banker
ARRANGEMENTS may be compensated for the sale of a mutual
revenue sharing or any other compensation
Clients should understand that compensation is not a prerequisite for a fund to be made fund. Referrals and recommendations are
received for networking, omnibus and available through Wells Fargo Advisors. made independent of compensation
platform services, revenue sharing, training, However, Wells Fargo Advisors, in its arrangements and based solely on the
education and other services varies between discretion, reserves the right in the future to client's needs and objectives.
fund families and even between funds within limit the mutual fund companies that do not
a particular family. Accordingly, a potential adequately support the firm's efforts or meet YOUR RELATIONSHIP WITH
conflict of interest exists when Wells Fargo other economic criteria. WELLS FARGO & COMPANY
Advisors receives more compensation from
one fund family (or from one fund) than it Wells Fargo Advisors incentive Wells Fargo appreciates your confidence and
receives from peer fund families (or from peer wants to make your brokerage and banking
programs relationships clear and convenient for you.
funds).
From time to time, Wells Fargo Advisors Your Wells Fargo Advisors Financial Advisor
Wells Fargo Advisors has adopted policies initiates incentive programs for all its team may serve as your Relationship Manager not
reasonably designed to control and limit members, including Financial Advisors. only for your brokerage accounts and
these potential conflicts of interest. These These programs include, but are not limited services with Wells Fargo Advisors, but also
policies include, but are not limited to, the to: programs that compensate associates for for products and services with Wells Fargo
following: attracting new assets and clients to Wells Bank, N.A, including trust accounts of which
Fargo Advisors or referring business to its you may be a beneficiary or agency accounts
• Require networking, omnibus, platform affiliates (such as referrals for mortgages, in which you may have an interest.
service fees and revenue-sharing trusts or insurance products); programs that
agreements to be in writing, and prohibit reward associates for promoting investment The responsibilities of Wells Fargo Advisors
agreements or provisions that call for advisory services; preparing Envision® and your Financial Advisor, when acting in a
Wells Fargo Advisors to provide investor reviews; participating in advanced brokerage or investment advisory capacity or
preferential marketing and promotional training; improving client service; and in introducing you to a banking product or
treatment to a fund family as a condition of programs that reward Financial Advisors who service, are different from the responsibilities
paying or receiving networking, omnibus, meet total production criteria. of Wells Fargo Bank and your Financial
platform service fees or revenue sharing Advisor when acting in a role as Relationship
fees. Financial Advisors who participate in these Manager for a Wells Fargo Bank trust or
incentive programs may be rewarded with agency account. Your Financial Advisor, in a
• Prohibit the sharing of any portion of
cash and/or non-cash compensation, such as brokerage or investment advisory capacity
networking fees, omnibus fees, revenue
deferred compensation, bonuses, training may recommend or assist you with a
sharing fees or intra-company
symposiums and recognition trips. Portions of transaction that does not concern the Wells
compensation with Financial Advisors in
these programs may be subsidized by Fargo Bank trust or agency account for which
their role as a Financial Advisor.
external vendors and Wells Fargo Advisors he or she will be compensated. If you decide

586380 (Rev 38 - 09/22) Page 10 of 21

to enter into such a transaction, you will
receive specific disclosures in connection
with the transaction, including all relevant
information and a description of the
compensation that your Financial Advisor will
receive. You will have the opportunity to ask
for more information about the compensation
to your Financial Advisor on such a
transaction.
If you have questions about any product or
service offered or what role your Financial
Advisor or any other Wells Fargo team
member is serving, or what compensation is
being paid with respect to any product or
service, please ask your Relationship
Manager or Financial Advisor.
Before buying any mutual fund, it is important
for you to read and understand the fund's
prospectus. If you have any questions about
a specific fund, or the information in the
fund's prospectus, contact your Financial
Advisor. Additionally, to learn more about
mutual funds in general, contact your
Financial Advisor or visit the following
websites:
Wells Fargo Advisors:
www.wellsfargoadvisors.com

Investment Company Institute:

www.ici.org

Financial Industry Regulatory Authority:

www.finra.org

Securities and Exchange Commission:

www.sec.gov

Securities Industry and Financial Markets

Association:
www.sifma.org

586380 (Rev 38 - 09/22) Page 11 of 21

FUND FAMILIES WITH AGREEMENTS WITH WELLS FARGO ADVISORS - as of March 2022
Legend of Fund Families
* Offshore funds only
** Includes domestic and offshore funds
*** Pays fixed amount based on a proprietary formula
**** Pays training and education compensation for domestic funds
† Networking and Omnibus Platform Agreement only
‡ Both Networking and Omnibus Platform and Revenue Sharing Agreement

1290 † Barrett † Credit Suisse ‡

13 D Activist † BBH † CRA Investment Funds †
1919 Investment Counsel Funds ‡ Beck, Mack and Oliver † CRM ‡
1WS Credit Income Fund † Becker Value † Cullen Funds (Schafer Cullen) ‡
361 Capital Fund/Hamilton Lane ‡ Biondo † Cushing Funds †
AAMA † BlackRock ‡ **/**** Cutler †
Abbey Capital ‡ Blackstone † Dana †
Aberdeen/Artio ‡ ** Bluerock † Davidson †
ABR † BMT Investment † Davis ‡ **
Absolute Strategies † BNY Mellon/Dreyfus ‡ **** Dean ‡
Acadian † Bogle Investment Management/Summitt † Dearborn †
ACAP † Boston Common ‡ Destra Investments †
ACR (Alpine Capital Research) † Boston Trust Walden ‡ DFA †
Advisor One † Boyar Value Funds † DF Dent †
Advisors Asset Management, Inc. (AAM) † Bramshill Income Preference † Diamond Hill ‡
Advisors Inner Circle † Brandes Inv. Partners ‡ Direxion ‡
Advisors Preferred/Kensington † Bridgeway Funds † Domini Funds ‡
AEGIS Financial Corp † Bridgehampton † Doubleline ‡
Ainn Funds † Broadview/Madison ‡ Driehaus ‡
Akre Funds † Brookfield ‡ DSM †
Al Frank Funds † Brown Advisory Funds ‡ Dunham Funds ‡
Alger ‡ Buffalo ‡ Dupree †
Alliance Bernstein ‡ ** Calamos ‡ DWS Investments ‡
Allspring Funds ‡ **** Caldwell Orkin † EAS †
Alpha Capital † Cambiar Funds † Easterly Fund, LLC/James Alpha ‡
Alpha Centric † CAN Slim/Duncan Hurst † Edgar Lomax †
ALPS ‡ Cantor FBP † Edgewood ‡
Altegris † Carlyle † Emerald ‡
Amana/Saturna/Sextant ‡ Carrillon/Eagle/Scout ‡ Empiric Funds ‡
American Beacon ‡ Catalyst Funds † Epiphany Funds †
American Century ‡ Causeway Capital ‡ Equinox Mutual Hedge Futures
American Funds ‡ ***/**** CenterStone † Strategy †
AMG Managers/Yacktman/Brandywine ‡ Centre † Equity Investment Corp (EIC) ‡
Amundi Asset Management US ‡ **/**** Champlain Funds † EuroPac †
Ancora † Chartwell † Eventide ‡
Angel Oak Capital Advisors ‡ Chase Investment Counsel ‡ Evermore †
Appleseed ‡ Chou † Fairholme Funds †
Appleton † CION † FAMCO †
AQR ‡ Clipper (part of Davis) ‡ Federated ‡ ****
Aquilia Group of Funds ‡ Clough † Fenimore Funds (FAM) ‡
AR Capital Real Estate † CM Advisors ‡ Fidelity Advisors ‡ **/****
Arbitrage † CMG † Fiera Capital ‡
Ariel Investments ‡ Cohen & Steers ‡ Fifth Third †
Arin Funds † Coho † First America †
Arrow ‡ Collar Fund † First Eagle ‡ ****
Artisan Funds ‡ Colorado BondShares/Freedom Funds † First Eagle Credit Opportunities Fund †
Ashmore ‡ Columbia/Threadneedle ‡ ** First Trust ‡ ****
ATAC/Pension Partners † Commonwealth Fund † Flat Rock †
AT Funds/CIBC Private Wealth Inv. † Conestoga ‡ FMI ‡
Auxier Focus Fund † Congress ‡ Forester Funds †
Axonic Strategic Income Fund † Convergence † Fort Pitt †
AXS † Cook & Bynum † Forum †
Baird † Copeland Trust † FPA Funds †
Baron ‡ Crawford † Franklin Templeton ‡ **/****

586380 (Rev 38 - 09/22) Page 12 of 21

Frank Value † Janus Henderson ‡ ** Navigator †
Friess Funds † Jensen † Needham Funds ‡
FS Investments/Chiron ‡ JOHCM ‡ Neuberger Berman ‡ **/****
FS Credit Income Fund † Jordan † New Alternatives Fund †
FS Multi Strategy Fund † John Hancock ‡ **** NexPoint Advisors †
Fuller & Thaler † JP Morgan ‡ **/**** Nicholas Group ‡
Fund X Upgrader † Keeley ‡ Niemann †
FundVantage Trust (Estabrook) † Kinetics ‡ Northern Funds †
Gabelli ‡ Kirr Marbach † Northern Lights Fund Trust †
Gave Kal † Ladenburg Thalman † Northern Lights Fund Trust II †
Geneva Advisors † Lateef † Northern Lights Fund Trust III †
Gerstein Fischer † Lazard ‡ Northern Lights Fund Trust IV †
GKM Funds † Leader Capital Corp. † North Square ‡
GMO † Leavell Investment Trust † North Star Real Est. †
Goehring & Rozencwajg Funds † Legg Mason/Legg Mason Partners/ Nuance †
Goldman Sachs ‡ **** Western Asset Management ‡ ** Nuveen ‡ ****
Good Harbor Financial, LLC ‡ Leuthold Funds † Oak Associates Funds †
Good Haven † Liberty Street Horizon Fund † Oakhurst †
Gotham † Lincoln/Delaware Funds/Ivy ‡ **** Oakmark Funds †
GQG ‡ Linde Hansen † Oberweis Funds †
Grandeur Peak † LKCM Funds (Luther King) † OCM Mutual Fund †
Grant Park † LoCorr ‡ Old Westbury †
Great Lake Funds/Wintrust † Logan † Olstein ‡
Green Century ‡ Longleaf † Orinda Funds †
Greenspring † Longview † O'Shaugnessy †
Green Square † Lord Abbett ‡ **/**** Osterweis Fund †
Griffin † LS Opportunities † Otter Creek Advisors †
Griffin Inst. Access Credit Fund † Lyrical † Pacific Funds ‡
Guggenheim/Rydex ‡ M360 † Pacific Investment Advisors (PIA) ‡
Guide Stone Funds † Madison Funds ‡ Palmer Square Capital Management †
Hamlin † Maingate MLP Funds ‡ Paradigm †
Harbor Fund † Mainstay ‡ Parnassus Funds ‡
Harding Loevner Funds † Mairs & Power † PAX World Mutual Fund Series I & III †
Hartford ‡ **** Manning & Napier ‡ Payden & Rygel Funds †
Harvest † Manor Funds † Performance Funds †
HCM † Marathon † Permanent Portfolios †
Heartland Funds ‡ Mass Mutual ‡ Perritt †
Hennessey ‡ Matrix † PGIM/Prudential ‡ ****
Heritage † Matthew 25 Fund † Phaecian †
Highland † Matthews Asia Funds ‡ PIMCO ‡ **/****
Hillman ‡ Matson † Pinnacle †
Homestead Funds † Mercator International Opportunity † Polaris †
Hotchkis & Wiley ‡ Merk † Polen ‡
HSBC † Merian Global Investors (UK) Poplar Forest †
Huber † Limited * Port Street †
Huntington/Rational † Meridian ‡ Powell Alt. Income Strategies †
Hussman † Mesirow Financial † Power Income Funds †
IM Global Partner U.S., LLC † Metropolitan West † Predex Funds †
IMST (Perimeter and LS Theta Fund) † MFS ‡ ** Prime Cap Odyssey Funds †
Investment Managers SeriesTrust † Midas Funds ‡ Principal ‡ **/****
IndexIQ Alpha † Miller ‡ Princeton †
Innealta † Miller Value ‡ Private Shares/Shares Post 100 †
Integrity Funds Distributor † Mirae † Profunds ‡
Intrepid † MMA Praxis Funds ‡ Provident †
Invesco ‡ **** Mondrian ‡ Putnam ‡ **
Investec/Ninety One * Monteagle † Quaker ‡
Ironclad † Morgan Stanley ‡ **/Eaton Vance/ RBC Funds ‡
ISI † Calvert ‡ **/**** Redwood †
Jackson Square ‡ Mutual Funds Series Trust † Reinhart Partners ‡
Jacob Funds † Nationwide ‡ Resource Credit Income †
James Advantage ‡ Natixis ‡ ** Rice Hall James †

586380 (Rev 38 - 09/22) Page 13 of 21

RiverNorth Capital ‡ Sound Shore ‡ Two Oaks †
RiverPark Funds † Southern Sun ‡ UBS Global Asset Management ‡
RMB/Burnham Funds ‡ Sparrow ‡ US Global Investors †
Robeco/Boston Partners ‡ Sprott † USA Mutuals †
Rondure † State Street ‡ USQ Core Real Estate Fund †
Roumell † Sterling Capital Fund ‡ Van Eck Global ‡
Royce ‡ Sunbridge † Variant Alternative Income Fund †
Russell ‡ **** Swan ‡ Versus Capital †
Salient Advisors/Forward ‡ Symmetry † Victory/Munder/RS/Compass EMP/
Scharf Funds † T. Rowe Price ‡ USAA ‡
Schroder Investment Mgmt. † ** Tanaka ‡ Villere Funds †
Schwab Funds † TCW Funds ‡ Virtus/Allianz/Merger ‡ ****
Schwartz Investment Counsel/Ave Teberg † Vivaldi †
Maria Funds ‡ The Motley Fool † Voya ‡
Seafarer † Third Avenue † VRM †
Segal Bryant & Hamill (SBH) ‡ Thomas White Funds † Vulcan Valve Partner †
SEI ‡ Thompson IM Funds † Wasatch Funds †
Selected ‡ Thornburg ‡ Walthausen †
Semper † Timothy Plan † WCM ‡
Sequoia † Tocqueville Funds ‡ Weitz Funds ‡
Seven Canyon ‡ Torray Funds ‡ Wellington Management †
Shelton Capital Management/ICON ‡ Tortoise Capital Advisors/Advisory Wildermuth †
Shenkman † Research ‡ William Blair ‡
Sierra Trust † Total Fund Solutions-Cromwell ‡ Wilmington ‡
Sierra Total Return † Touchstone Funds ‡ **** Williamsburg Government †
SilverPepper ‡ Transamerica Capital ‡ Wilshire Funds †
SIT Funds ‡ Tributary ‡ World Funds †
Smead † Trillium/Portfolio 21 † X-Square Balanced Fund †
Sound Mind ‡ Tweedy, Browne † YCG †
Not all products, services or investments are available for sale in all countries. The information contained in these pages is not an offer to sell or a
solicitation of an offer to buy any investment mentioned herein, and no offers or sales will be made in jurisdictions in which the offer and sale of the
investment is not authorized, qualified or is exempt from regulation.
Offshore mutual funds are not registered under the United States Investment Company Act of 1940, as amended, or the United States Securities
Act of 1933, as amended. These products are NOT for sale to U.S. Citizens anywhere in the world or clients residing on U.S. soil. Investors should
read the Key Investor Information Document and the Prospectus prior to investing.
Wells Capital Management Incorporated, Wells Fargo Funds Management, LLC, Wells Fargo Asset Management (International) LLC, Wells Fargo
Funds Distributor, LLC and Galliard Capital Management, Inc. will no longer be related persons of WFCS. These companies were wholly owned by
Wells Fargo & Company (“Wells Fargo”) and formed the asset management business that Wells Fargo operated under the trade name Wells Fargo
Asset Management. These companies served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the separately
managed account programs offered through WFCS. Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners
subsequently renamed the business Allspring Global Investments. The sale closed on November 1, 2021.
Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings,
LLC. This group of companies includes Allspring Funds Management, LLC, the investment adviser to each of the mutual funds within the Allspring
Global family of funds, and Allspring Funds Distributor, LLC, the principal underwriter of the Allspring Global mutual funds. It also includes Allspring
Global Investments, LLC, an investment adviser to pooled investment vehicles and separately managed accounts.
Wells Fargo will have no role in the management of Allspring. However, Wells Fargo will retain less than a 10% equity ownership interest in
Allspring and, for a limited period of time following the close of the sale, continue to provide research and certain non-advisory transition services to
Allspring for a fee. WFCS will continue to receive compensation from Allspring for the distribution, administrative and operational services that we
provide to the Allspring Global mutual funds. Additionally, WFCS and Wells Fargo Investment Institute, Inc. will continue to provide Allspring, for a
fee, with thematic recommended lists and research regarding individual equities used by Allspring to construct portfolios for separately managed
accounts that are exclusively distributed by WFCS and its related persons. For a limited period of time, WFII will also continue to provide manager
research to Allspring for a fee.
Wells Fargo's equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services and research to
Allspring for a fee will provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by
Allspring, including mutual funds, sweep vehicles, and separately managed account programs. Although Allspring will not be a related person of
WFCS, WFCS and its related persons will continue to benefit from the sales of these products to a greater extent than the sale of other third-party
products in which we do not have a similar financial interest.
Wells Fargo Bank, N.A. is an affiliate of Wells Fargo Advisors and a subsidiary of Wells Fargo & Company.

Investment and Insurance Products are:

• Not Insured by the FDIC or Any Federal Government Agency
• Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate
• Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested
Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC (WFCS), Member SIPC, a registered broker-dealer and
non-bank affiliate of Wells Fargo & Company. WellsTrade brokerage accounts are offered through WFCS.
© 2012-2022 Wells Fargo Clearing Services, LLC. CAR-0422-03430 IHA-7250582 e6244

586380 (Rev 38 - 09/22) Page 14 of 21

 • Your age, other investments, financial not the equivalent of investing directly in the
3. A GUIDE TO INVESTING situation and needs, tax status, investment actual physical commodity, currency, or
IN EXCHANGE-TRADED objectives, investment experience,
investment time horizon, liquidity needs,
volatility instrument. Futures-linked ETPs are
complex investment vehicles and, as a result
PRODUCTS and risk tolerance. of the use of futures contracts and swaps, are
subject to unique risks and characteristics.
What you should know before • The security’s investment objectives,
Futures-linked ETPs are generally passively
characteristics (including any special or
you buy managed. These products may be volatile
unusual features), liquidity, volatility, and
and may use leverage. As a result of their
Before you make an investment decision, it is likely performance in a variety of market
complex structure, their performance may not
important to review your financial situation, and economic conditions.
necessarily correspond to the underlying spot
investment objectives, risk tolerance, time • For complex products, you should price performance (the spot price is the price
horizon, diversification needs, and liquidity consider whether less complex or costly of goods, currencies, or securities that are
objectives with your financial advisor. This products achieve the same objectives. offered for immediate delivery and payment).
guide will help you better understand the In fact, when there are significant differences
features and costs associated with exchange- By accepting a recommendation, you between the spot price and the futures price,
traded products, as well as how your financial acknowledge that you have considered the the performance of the ETP may be very
advisor and Wells Fargo Advisors are above factors to your satisfaction. dissimilar to the spot price performance and
compensated when you invest in these may adversely impact your return. This
products. ETP STRUCTURES deviation could be positive or negative
Exchange-traded products (ETPs) depending on market conditions and
This guide provides an overview of the
encompass a number of structures which investment strategy.
various types and structures of exchange-
typically track an underlying benchmark,
traded products (ETPs) and some of the The difference between the performance of
index, or portfolio of securities. ETPs may be
characteristics of each. It also describes futures-linked ETPs and the underlying spot
structured as exchange-traded funds (ETFs),
complex “futures-linked” ETPs, as well as price may also be affected by the “rolling” of
exchange-traded notes (ETNs), grant or
non-traditional ETPs. As further described contracts by the fund manager. For instance,
trusts, or commodity pools.
below, these and other exchange-traded the manager wants to have ongoing,
products may seem similar, but their Exchange-traded funds (ETFs) continual exposure to the particular
functional risks and characteristics are quite commodity (or commodities) by using futures
The majority of ETPs are typically structured
different. contracts or swap contracts. Therefore, if the
as registered unit investment trusts (UITs) or
open-end investment companies (commonly manager is long (or holds) the contract, the
WHAT ARE EXCHANGE-TRADED manager must liquidate the contract that is
referred to as “funds”) whose shares
PRODUCTS? represent an interest in a portfolio of currently held, sometime before expiration,
securities that track an underlying benchmark and then gain exposure to another contract
Exchange-traded products (ETPs) at their with a later expiration. The manager must
core are securities which derive their value or index. These products are the most
common type of ETP, and typically hold a continually liquidate and buy in contracts as
from a basket of securities such as stocks, the contracts’ expiration dates approach.
bonds, commodities, or indices, and are basket of equity or fixed income securities
constructed to track an index. When commodity futures-linked securities are
traded similar to individual stocks on an rolled, the difference between the price of the
exchange. When you purchase an ETP, you contract it sells and the price of the new
are purchasing shares of the overall portfolio, Exchange-traded notes (ETNs)
Exchange-traded notes (ETNs) are not funds, contract it buys is called the “roll yield.” The
not the actual shares of the underlying effect of rolling contracts will vary depending
investments or index components. Passively- are not registered under the Investment
Company Act of 1940, and are not subject to on whether a particular commodity or futures
managed ETPs can track a wide variety of market is in “contango” or “backwardation.”
sector-specific, country-specific, and broad- the same regulatory requirements as mutual
funds, closed-end funds, or exchange-traded Contango and backwardation are unique
market indices, while actively-managed ETPs risks associated with futures.
do not track any particular index. ETPs may funds. ETNs are senior, unsecured debt
provide diversification to your overall portfolio obligations issued by a financial institution
and are typically designed to track the total
Contango
because one share or one unit may represent When a market is in contango, contracts for
multiple underlying stocks, bonds, and/or return of an underlying index. ETNs do not
have principal protection and are at the risk of more distant future delivery are more
other asset classes. expensive than near-term contracts for the
the creditworthiness of the issuer.
Passively-managed ETPs seek to track the same commodity. Accordingly, if contracts
market performance of the underlying index Grantor trusts and commodity pools are rolled in an attempt to maintain a long
that makes up its basket of securities, ETPs that hold commodities, currencies, position while in contango, then the result is a
whereas actively-managed ETPs are not tied commodity- or currency-based instruments, loss or a negative roll yield.
to a specific index. Although passive ETPs or volatility instruments may be structured as
seek to mirror the performance of a particular grantor trusts or commodity pools, depending
Backwardation
index, the relationship between performance on the type of underlying instrument. ETPs Backwardation is the opposite of contango.
of the index or sector and the passive ETP is that hold physical bullion or currency are Backwardation is when more distant futures
not exact because of the fees and trading typically structured as grantor trusts. contracts are less expensive than the near-
costs associated with the ETP, as well as the However, ETPs that obtain exposure to term contracts, possibly resulting in a gain
difficulties in exactly mimicking an index. commodities or other asset classes through when rolling. Thus, backwardation generally
the use of futures or forwards contracts are results in a positive roll yield for an investor
We have a responsibility to consider commonly structured as commodity pools. who is long on futures contracts and rolls into
reasonably available alternatives in making a Grantor trusts and commodity pools are not contracts with a later expiration.
recommendation. We do not need to evaluate registered as investment companies and do
every possible alternative either within our It is important that you understand how
not have the protections of the Investment futures-linked ETPs are structured, in
products or outside the firm in making a Company Act of 1940. Tax consequences
recommendation. We are not required to offer addition to understanding the risks and
vary depending on the structure and characteristics of purchasing investments that
the “best” or lowest cost product. While cost underlying instruments used in each ETP.
is a factor that we take into consideration in focus on futures trading prior to purchasing a
Consult your tax advisor to determine the futures-linked ETP.
making a recommendation, it is not the only impact to your individual tax picture.
factor. Futures-linked ETPs are not appropriate for
You should consider factors such as those
FUTURES-LINKED ETPS all investors. The performance of the future-
below prior to accepting a recommendation: Many commodity, currency, or volatility ETPs linked ETPs does not necessarily replicate
attempt to track a futures-based index. the spot price and can deviate significantly
• The potential risks, rewards, and costs in Typically, these ETPs invest all their assets in from the performance of the spot price of the
purchasing and in the future selling of a a pool which may hold futures contracts, referenced commodity.
security. swaps, and/or forward contracts. They are

586380 (Rev 38 - 09/22) Page 15 of 21

ACTIVELY-MANAGED ETPS generally engages in trading strategies, such diversification. Alt ETPs are not appropriate
as short selling, or enters into total return for all investors, and it’s important to
An actively-managed ETP is an exchange- swap agreements and futures contracts. An understand the strategy of the ETP you are
traded fund that is managed by a single or inverse ETP seeks to deliver the inverse (-1x) purchasing.
team of fund managers. Actively managed of the index’s performance, while a two times
exchange-traded funds do not seek to (-2x) or three times (-3x) leveraged inverse In addition to the aforementioned
replicate the performance of a specific index. ETP seeks to deliver two or three times the characteristics, Alt ETPs may have relatively
Instead, they use an active investment opposite of the index’s performance, higher expense ratios when compared to
strategy to meet their investment objective. In respectively. To accomplish their objectives, traditional ETPs. Please see the ETP’s
an actively managed ETP, portfolio managers non-traditional ETPs involve investment prospectus for details, as well as other
may amend investment allocations, based on strategies that utilize swaps, futures characteristics and potential risks.
their market views, while remaining within the contracts, and other derivative instruments.
parameters of the funds’ stated investment Both leveraged and inverse non-traditional ETPS TRACKING
policies. ETPs are trading vehicles and are not ALTERNATIVELY WEIGHTED
appropriate for investors who are interested INDICES
SEMI-TRANSPARENT ETPS in a buy-and-hold strategy, particularly in
Traditional ETPs disclose their holdings to volatile markets. Indexing has continued to expand beyond
the public on a daily basis, semi-transparent traditional market capitalization weighted
ETPs do not do this. Semi-transparent ETPs Volatility-linked ETPs methods to alternatively weighted strategies
are actively-managed and disclose their Another type of non-traditional ETPs are (e.g., using equally weighted, fundamentally
holdings either monthly or quarterly with a those with exposure to futures contracts tied weighted, volatility weighted indices). These
lag. The differences between these ETPs and to the CBOE SPX Volatility Index (better indices provide exposure to specific
traditional ETPs has an advantage for the known as the VIX). These products use investment risk factors or strategies. They
managers. By keeping certain information various complex methodologies to gain generally begin with securities from a broad-
about these ETPs secret, these ETPs may exposure to the VIX, and are not designed to based index and apply a set of rules to
face less risk that other traders can predict or be long-term investments. It is not possible to determine a portfolio of securities believed to
copy its investment strategy. However, in invest directly in the VIX, and the use of VIX provide the greatest potential for capital
order for to make a market for the ETP to futures contracts in these products creates appreciation, total return, or other investment
trade, the ETP sponsor provides a sample or potential for significant long-term deviation objective. Products tracking such indices may
basket of securities of the portfolio to market from the VIX. or may not provide superior risk-adjusted
makers that is used to price the product. As performance relative to products tracking
such, there is a risk that the performance of Non-traditional ETPs are not appropriate for more traditional capitalization weighted
the ETP will not exactly match the most investors. The effects of mathematical indices.
performance of the strategy itself. This risk compounding can grow significantly over
may be greater in uncertain market time, leading to scenarios whereby ETPs that track alternatively weighted indices
conditions. performance over the long run can differ may or may not provide superior risk-
significantly from the performance (or inverse adjusted returns when compared to
Non-traditional ETPs performance) of their underlying index or traditional market cap weighted indices.
Involve investment strategies that utilize benchmark during the same period of time Products tracking these indices may be
swaps, futures contracts, and other derivative leveraged, inverse, leveraged inverse, and unfamiliar, moreover, ETPs tracking these
instruments, and therefore introduce other complex ETPs may be more volatile indices may be thinly traded and have wide
counterparty risk. They are complex financial and risky than traditional ETPs due to their bid ask spreads making these funds more
instruments typically designed to deliver exposure to leverage and derivatives, costly to trade, in addition to their generally
multiples of the performance of the index or particularly, total return swaps and futures. In higher internal expenses. It is uncertain how
benchmark they track on a daily or monthly addition, these instruments are typically these products will behave in different market
basis. However, these products may designed to achieve their desired exposure environments. Please see the ETP’s
significantly deviate from their expected on a daily (in a few cases, monthly) basis. prospectus for details, as well as other
return due to market volatility, use of Holding leveraged, inverse, and leveraged characteristics and potential risks.
leverage, and periodic resets. inverse ETPs for longer periods of time
potentially increases their risk due to the FEATURES AND
Leveraged ETPs effects of compounding and the inherent CHARACTERISTICS
Leveraged ETPs attempt to track a multiple difficulty in market timing.
Some key features and characteristics
of the daily (or monthly) returns of an index associated with ETPs include:
usually by using total return swaps. A
Alternative ETPs
leveraged ETP may be two times (2x) or Alternative exchange traded products (alt Tax efficiency
three times (3x) or other leverage multiples, ETPs) seek to accomplish the fund’s
objectives through non-traditional Traditional ETPs are generally not actively
which means it attempts to provide two or managed and, as a result, typically generate
three times the daily index return or loss, investments and trading strategies. Alt ETPs
might invest in assets such as global real fewer capital gains due to the low turnover of
respectively. For instance, the double the securities within their portfolio. Taxes
leveraged ETP seeks to provide a 2% gain estate, commodities, leveraged loans, start-
up companies, and unlisted securities that must be paid on all distributions made by the
on that daily return for each 1% increase in underlying securities and any capital gains
the market index return. Conversely, if the offer exposure beyond traditional stocks,
bonds, and cash. associated with transactions made by the
index drops 1%, your loss, in theory, would fund. However, because ETPs offer in-kind
be 2% for that given day, assuming the ETP The strategies alternative ETPs employ may redemptions to qualified entities, they can
is rebalanced daily. Non-traditional ETPs use be complex. Examples include hedging and avoid realizing capital gains for the fund
of leverage in an investment portfolio can leveraging through derivatives, short selling, although shareholders must still pay any
magnify any price movements resulting in and “opportunistic” strategies that change taxes on realized gains. Non-traditional ETPs
high volatility and potentially significant gain with market conditions as various may not be tax efficient due to the increased
or loss of principal. In addition, the use of opportunities present themselves. Some alt amount of portfolio turnover due to periodic
leverage, coupled with periodic portfolio ETPs employ single strategy (single-strategy rebalancing as well as the use of leverage. If
resets, may cause the investment funds), while other ETPs may utilize multiple you have questions about the possible tax
performance to deviate significantly from the strategies within the same ETP. consequences associated with these funds,
stated objective if held over multiple trading you should consult your tax advisor before
sessions. Alt ETPs are managed to a wide range of making any investment decision.
investment objectives. In some cases, the
Inverse ETPs ETP’s primary objective may be to generate Expense ratios
Some leveraged ETPs are inverse or “short” above-market returns. In other cases, an Management fees and operating expenses
funds, meaning that they seek to deliver the ETP’s main goal may be to help investors are charged by the fund management
opposite of the performance of the index or better manage risk with strategies designed company to cover the costs associated with
benchmark they track. An inverse ETP to smooth out volatility or offer greater management, marketing, and fund

586380 (Rev 38 - 09/22) Page 16 of 21

administration costs. Fees may vary Credit risk Investment Company Act registration
depending upon the fund manager’s trading ETNs are senior, unsecured debt obligations ETNs, as well as other ETPs holding futures,
activity. ETPs follow a unitary or non-unitary issued by a financial institution and are bullion, or demand deposits are typically not
fee structure and expenses may fluctuate typically designed to track the total return of registered under the Investment Company
over time. Purchases and sales of ETPs are an underlying index. ETNs do not have Act of 1940. Shareholders do not have the
subject to brokerage commissions. All fees principal protection, are at the risk of the protections associated with ownership of
and expenses are described in detail in the creditworthiness of the issuer, and do not pay shares in an investment company registered
prospectus. interest during their term. under the Investment Company Act. The
Investment Company Act is designed to
Transparency Fixed income ETPs protect investors by preventing: insiders from
The securities in most ETP portfolios are It is possible to lose money by investing in managing investment companies to their
made public every day, with the exception of ETPs (including ETPs with defined maturity benefit and to the detriment of public
some actively-managed ETPs that do not dates) holding fixed income securities, investors; the issuance of securities having
disclose holdings on a daily basis. Since especially during periods of rising interest inequitable or discriminatory provisions; the
passively-managed securities generally trade rates. Bond prices are negatively correlated management of investment companies by
within an index or sector that the ETP follows, to interest rates, so as general market irresponsible persons; the use of unsound or
you may be able to determine the positions interest rates rise, the price of a bond could misleading methods of computing earnings
within the portfolio at any time. You may find decrease. The greater the movement in and asset value; changes in the character of
this beneficial because the transparency interest rates, the greater impact potential on investment companies without the consent of
could allow you to have more control over a bond’s price. The opposite is true as well; if investors; and investment companies from
your overall investment portfolio allocation rates fall, bond prices could rise. Bond ETPs engaging in excessive leveraging. To
and weightings. are subject to the same risks as their accomplish these ends, the Investment
underlying investments which may include, Company Act requires the safekeeping and
Portfolio diversification (access to but are not limited to, credit quality, duration, proper valuation of fund assets, restricts
wide range of sectors) liquidity, and security structure. Fixed income greatly transactions with affiliates, limits
ETP portfolios can be diversified across ETPs are not cash alternatives or money leveraging, and imposes governance
many different securities, offering a set of market fund equivalents. You should not buy requirements as a check on fund
portfolios for almost every asset allocation a fixed income ETP based solely on the yield. management.
need. This diversification can help reduce an It is important to consider all risks and
investor’s risk by potentially offsetting losses characteristics of a bond ETP when making Liquidity
from some securities with gains in others. your investment decision. Securities within an ETP may be subject to
Bear in mind, diversification cannot liquidity risk. Liquidity risk exists when
guarantee a profit or protect against loss in a Floating rate ETPs particular investments are difficult for a fund
declining market. Floating rate ETPs invest primarily in below sponsor to purchase or sell. This can reduce
investment grade securities (also known as the returns of an ETP because the sponsor
Buying and selling flexibility junk bonds). The securities held within may not be able to transact at advantageous
ETPs are priced and can be purchased and floating rate ETPs are often rated below times or prices.
sold throughout the trading day. Furthermore, investment grade by one or more of the
you can buy or sell ETP shares on a stock nationally recognized rating agencies or may Management risk
exchange much like the purchase or sale of not be rated by a rating agency. These Actively-managed ETFs are subject to
any other listed stock. securities may offer higher than average management risk. In managing the fund’s
yields but are considered speculative and portfolio securities, the Investment Advisor
RISKS carry increased risks of price volatility, will apply investment techniques and risk
Until recently, traditional ETPs have generally underlying issuer creditworthiness, illiquidity, analyses in making investment decisions for
not been actively managed. This means that and the possibility of default in the timely the fund, but there can be no guarantee that
securities in the portfolio will not be payment of interest and principal, which may these will produce the desired results.
purchased or sold in an attempt to take impact the value of your portfolio. These
advantage of changing market conditions. A ETPs should not be considered as an Market risk
traditional ETP may continue to hold alternative to money market funds. You An ETP may continue to hold securities even
securities even though their market value and should carefully consider the risks of these though their market value and dividend yields
dividend yields may have changed. An ETP products and not base your investment may have changed. An ETP generally carries
generally carries the same investment risk as decision solely on the yield offered by the the same investment risk as the portfolio of
the portfolio of securities that comprises the ETP. securities within the ETP. Securities in a
index tracked within the ETP. Securities in a portfolio may depreciate, and the ETP may
portfolio may depreciate, and the ETP may
Halting of creations not achieve its intended objective. In addition,
not achieve its intended objective. In addition, The ability of ETP sponsors to perpetually each ETP is subject to specific risks that vary
each ETP is subject to specific risks that vary create new shares allows ETPs to efficiently depending on each ETP’s investment
depending on each ETP’s investment and accurately track their respective indices. objectives and portfolio composition.
objectives and portfolio composition. However, sponsors may choose at their
discretion to cease creating new shares, MLP ETPs
Call, early redemption, and which may lead the ETP to trade at While Wells Fargo Advisors does not provide
acceleration risk significant premiums to the value of their tax advice it is important to note that Master
underlying holdings or index. Limited Partners (MLPs) ETPs may be
Some ETNs are callable at the issuer’s
discretion. In some instances, ETNs can be International ETPs classified for federal income tax purposes as
subject to early redemption or an a taxable regular corporation, or Subchapter
ETPs may invest in foreign securities and “C” corporation. Subchapter “C” corporations
“accelerated” maturity date at the discretion currencies of developed, emerging market,
of the issuer or one of its affiliates. Since accrue deferred tax liability, if any, and may
and frontier market countries. These reduce the ETP’s net asset value. Return of
ETNs may be called at any time, their value investments (equity and fixed income) may
when called may be less than the market Capital distributions made by the ETP may
be subject to increased risks and could lose reduce your cost basis, and therefore, may
price paid, or even zero, resulting in a partial value as a result of political, financial, and
or total loss of your investment. increase your tax liability upon selling the
economic events in foreign countries. It is ETP. Please contact your tax advisor for
Concentrated products also important to keep in mind that foreign specific tax advice.
investments typically have less publicly
Some ETPs may be concentrated by the available information than U.S. investments, MLP ETPs have their own unique investment
number of holdings or within a particular are subject to less stringent foreign securities risks. For more information on MLP risk, see
industry or sector. Such concentration may regulations than domestic securities, and are the A Guide to Investing in Master Limited
make the value of an ETP more susceptible influenced by different factors than in the U.S. Partnerships at
to portfolio fluctuation.
(www.wellsfargoadvisors.com/guides). For
additional fund specific risks, please see the

586380 (Rev 38 - 09/22) Page 17 of 21

fund’s prospectus. Counterparty risk aliens may be subject to special tax
ETPs that use derivative instruments may withholding and reporting requirements as a
Municipal bond ETPs enter into contracts with a counterparty. As a result of an ETP sale. Certain ETPs may be
It is possible to lose money by investing in result, an ETP is subject to credit risk with subject to the alternative minimum tax (AMT).
ETFs (including ETPs with defined maturity respect to the amount it expects to receive Shareholders should review the prospectus
dates) holding municipal fixed income from counterparties to swaps and forward for further details. Shareholders should
securities, especially during periods of rising contracts entered into as part of that ETP’s review the prospectus for further details.
interest rates. Investments in municipal principal investment strategy. If counterparty
securities are subject to the creditworthiness Neither Wells Fargo Advisors nor your
becomes bankrupt or otherwise fails to financial advisor can offer tax, legal, or
of their issuers. Municipal bond ETPs are perform its obligations due to financial
subject to the same risks as their underlying accounting advice. As a result of complex
difficulties, an ETP could suffer significant tax-reporting requirements, investors should
municipal securities. Economic issues may losses on these contracts and the value of an
impact the performance of the municipal consult with their tax advisor or attorney
investor’s investment in an ETP may decline. before investing in ETPs.
bond issuer, as a result, principal is at risk
and subject to fluctuation. For instance, if the Speculative in nature COSTS OF INVESTING IN ETPS
underlying municipality defaults or the Non-traditional ETPs are speculative trading
security is downgraded, a decrease in the vehicles, appropriate only for sophisticated Transaction fee
value of these securities may impact your investors. You should not own a non- You will be assessed a transaction fee for
portfolio. Some single-state municipal bond traditional ETP if you are unable to bear the purchases and sales of ETPs through Wells
ETPs may offer certain tax benefits, but may associated market risk and the potential loss Fargo Advisors. ETPs offered by Wells Fargo
lack the diversification of a national fund. of principal. Non-traditional ETPs are not Advisors may be purchased in an advisory
Single state municipal ETPs can, and often appropriate for all investors. account without a transaction fee. Your
do, hold securities from outside that state — financial advisor does not receive
including U.S. territories. Holding period compensation from the transaction fee.
Net asset value risk Positions in non-traditional ETPs should be
monitored closely due to their volatile nature Spread costs
The value of the securities, or net asset value and inability to track the underlying index ETP transactions are subject to spread costs.
(NAV), within an ETP, may move up or down, over an extended period of time. Non- The bid/ask spread is the difference between
sometimes rapidly and unpredictably. The traditional ETPs are not intended to be held the price an ETP is offered for purchase (the
NAV at any point in time may be worth more long term. ask/offer price) and the price an ETP can be
or less than the value at the time of the sold (the bid price). In periods of low liquidity
original investment, even after taking into Leverage (for the underlying securities or the ETP
account any reinvestment of dividends and Non-traditional ETPs use of leverage in an shares themselves), bid/ask spreads may
distributions. investment portfolio can magnify any price widen considerably which in turn magnifies
Performance risk movements resulting in high volatility and the cost of the security transaction. As
potentially significant gain or loss of principal. spreads widen, the difference between the
ETPs are either passively managed or
In addition, the use of leverage, coupled with ETP Market Price and the ETP’s Net Asset
actively managed. Passively managed ETPs
periodic portfolio resets, may cause the Value may be magnified. Trading ETPs with
seek to mirror the index, therefore it is
investment performance to deviate large spreads can affect potential returns
unlikely that the investment will outperform
significantly from the stated objective if held since they affect the price at which an ETP is
the index because the securities in the
over multiple trading sessions. purchased or sold.
portfolio may not be purchased or sold in an
attempt to take advantage of changing Volatility Premium/discount risk
market conditions. Actively managed ETPs
do not seek to replicate the performance of ETP prices change throughout the trading The market price of an ETP may trade at a
an index. Portfolio managers make day as investors buy and sell shares in the higher price (premium) or lower price
investment decisions in an attempt to take marketplace. The availability of a continuous (discount) to its NAV. The size of the
advantage of market conditions, but there is market value pricing allows investors the premium or discount can vary significantly
no guarantee that the ETP will achieve its capability to both take advantage of and be at based upon multiple factors, including, but
investment objective. risk of market fluctuations. Investment returns not limited to: 1) demand for the underlying
will fluctuate subject to market volatility, so assets; and 2) liquidity of the ETP shares.
Tracking risk that when shares are redeemed or sold, the
ETPs may not track the underlying index due investment may be worth more or less than INVESTOR CHARACTERISTICS
to imperfect correlation between the ETP’s the principal investment. Due to their volatile ETPs are not appropriate for all investors.
portfolio securities and those in the nature, non-traditional ETP performance can Selecting an ETP for your investment
underlying index, rounding prices, changes to change significantly from their stated objectives involves a number of factors: fund
the underlying index, and regulatory objective. You can lose money investing in strategies, fund performance history, risks,
requirements. This risk may be heightened non-traditional ETPs. and investment time horizon. You should
during times of increased market volatility or Each type of ETP offers unique risks and review any ETP’s disclosure document, as
other unusual market conditions. Tracking characteristics. Please refer to the well as the fund prospectus, to fully evaluate
error also may result because the ETP incurs prospectus for additional details. your options. You should also talk with your
fees and expenses while the underlying index financial advisor so that, together, you can
does not. TAX TREATMENT make the choices appropriate for you. Non-
traditional ETPs and futures-linked ETPs are
Trading hours With the exception of ETNs, most ETP appropriate only for sophisticated and
Underlying holdings of certain ETPs may shareholders are subject to income taxes on speculative investors as well as institutional
have significantly different trading hours than the interest, dividends, and/or capital gains clients who fully understand the complexities
the ETP themselves. While it is possible to distributed to them from the portfolio. of these products and the significant risks
trade ETPs when the markets of their However, in retirement accounts such as that exist in purchasing or trading in them.
underlying holdings are closed, premiums individual retirement accounts (IRAs), taxes Non-traditional ETPs and futures-linked ETPs
and discounts may widen during those times. are deferred until distributions are taken from are for individuals who have a high tolerance
the account. Also, when an investor sells the for risk as well as the ability and willingness
Non-traditional ETPs and futures-linked ETP position, he or she will generally realize to absorb potentially significant losses. An
ETPs are complex products and should only a taxable gain or loss that should be reported increase in market volatility relative to the
be purchased by sophisticated investors who on their income tax returns. level of expected return in the underlying
understand the speculative nature of these index, commodity, or other related products
products. As a result, these products are To gain certain exposures, a fund may utilize
an offshore subsidiary that is wholly-owned may negatively impact your expected return.
subject to a number of risks that transcend
those of traditional ETPs. These risks may by the fund. A change in tax law or regulation Non-traditional ETPs are not designed to be
include, but are not limited to, the following: could adversely affect the way the fund is used as long-term investment vehicles.
taxed, operated, and managed. Nonresident

586380 (Rev 38 - 09/22) Page 18 of 21

Many non-traditional ETPs rebalance on a for training and education and payments for meetings, seminars, or other events gain an
daily or monthly basis. Due to the ETP data related to sales activities conducted opportunity to build relationships with
compounding of daily or monthly returns, the by Wells Fargo Advisors with respect to ETPs financial advisors; these relationships could
actual return of a non-traditional ETP may of such ETP product sponsors. lead to additional sales of that particular fund
differ greatly from the return of a traditional company’s products.
ETP. The use of +2x or +3x leveraged ETPs Please note that these compensation
does not guarantee double or triple the arrangements are described in the ETP sponsor policies can be found in an
return, respectively, during any single or prospectus and the Statement of Additional ETP’s prospectus, which is available on
multiday holding period. Information (SAI), a supplementary document request from the ETP product sponsor. If you
to the prospectus, for each ETP offered by have any questions about these practices,
TALK TO YOUR FINANCIAL Wells Fargo Advisors. We included this please contact your financial advisor.
section to provide you with enhanced
ADVISOR disclosure about the compensation DATA AGREEMENTS
Determining whether ETPs are an arrangements between Wells Fargo Advisors Wells Fargo Advisors also provides
appropriate investment strategy for you and ETP product sponsors and any aggregated sales data to ETF sponsors
requires an in-depth evaluation of your associated potential conflicts of interest. relating specifically to such sponsor’s ETFs.
individual financial situation and the The annual payment is $650,000 for ETF
objectives you want to achieve. Talk with TRAINING AND EDUCATION sponsors wishing to purchase such data. This
your financial advisor today about how ETPs COMPENSATION presents a conflict of interest for Wells Fargo
may help you work toward your investment Advisors and its financial advisors to the
goals. Wells Fargo Advisors offers multiple ways for
product sponsors to provide training and extent it leads us to focus more on sponsors
that purchase the ETF data over those that
Diversification education to our financial advisors in local
do not. To mitigate this conflict, our financial
Wells Fargo Advisors believes that investors branch offices or in larger group settings,
including at the national level. advisors do not receive any additional
should diversify their investment portfolios. It compensation for recommending ETFs from
is recommended that investors observe an • Certain product sponsors have agreed to sponsors that purchase the data.
asset allocation strategy and not overweigh dedicate resources and funding to provide
their overall portfolio in any one class or this training and education at our POTENTIAL CONFLICTS OF
sector of securities, including the underlying
portfolio within an ETP. Although asset
nationally-organized events. This INTEREST ASSOCIATED WITH
commitment could lead our financial
allocation can be an effective investment advisors to focus on the ETPs offered from ADDITIONAL COMPENSATION
strategy, it cannot eliminate the risk of these product sponsors versus those ARRANGEMENTS
fluctuating market prices and uncertain offered by families, which are not
returns. Clients should understand that
represented during support sessions.
reimbursements received for training and
HOW YOUR FINANCIAL ADVISOR • Wells Fargo Advisors selects the product education varies between product sponsors.
AND WELLS FARGO ADVISORS sponsors that participate in the training Accordingly, a potential conflict of interest
and education events based on a variety exists when Wells Fargo Advisors receives
ARE COMPENSATED ON ETPS of qualitative and quantitative criteria. The more reimbursement from one product
For helping you invest in an ETP, Wells subset of product sponsors that offers this sponsor/fund than it receives from peer
Fargo Advisors and your financial advisor are support and participates in nationally product sponsors/peer funds.
compensated in ways that vary depending on organized training and education events
may change periodically. Wells Fargo Advisors has adopted policies
the selected investment. Your financial
advisor will receive compensation in the form reasonably designed to control and limit
• Product sponsors may also provide
of a commission from most transactions. For these potential conflicts of interest. These
compensation to offset or reimburse Wells
most purchases, a financial advisor’s Fargo Advisors for costs incurred in policies include, but are not limited to, the
compensation is based on the dollar amount conducting comprehensive training and following:
purchased or sold in the ETP transaction. In educational meetings for its financial • Require training and education and data
certain fee-based accounts, a financial advisors. These meetings or events are agreements to be in writing, and prohibit
advisor’s compensation is based on a held to teach financial advisors about the agreements or provisions that call for
percentage of assets in the account rather product characteristics, sales materials, Wells Fargo Advisors to provide
than on the concession as mentioned above. customer support services, and successful preferential marketing and promotional
The compensation formula that determines sales techniques as they relate to various treatment to a product sponsor as a
the amount of payment to your financial ETPs. condition of paying or receiving these fees.
advisor is generally the same for all ETPs.
• Separately, product sponsors may host • Prohibit the sharing of any portion of
Wells Fargo Securities (WFS) may receive financial advisors for education and training and education and data to be
compensation for making a market and conferences at the fund company shared with financial advisors in their role
keeping an inventory on select ETP offerings. headquarters, regional office, or other as a financial advisor.
WFS may have an investment banking locations. Likewise, occasionally, product
relationship with ETP issuers. Wells Fargo sponsors will reimburse Wells Fargo • Require reimbursement payments for
Securities is the trade name for the capital Advisors for expenses incurred by general educational and training expenses
markets and investment banking services of individual branch offices in connection with and for expenses associated with
Wells Fargo & Company and its subsidiaries, conducting training and educational conducting individual branch office
including Wells Fargo Securities, LLC, meetings, conferences, or seminars for training, and educational activities to be
member NYSE, FINRA and SIPC and Wells financial advisors and customers. Also, recorded and approved.
Fargo Bank, N.A. Wells Fargo Bank, N.A. is a financial advisors may receive promotional • Limit the annual dollar value of gifts or
bank affiliate of Wells Fargo & Company. items, meals, entertainment, or other other noncash items that product sponsors
noncash compensation from product and their representatives can provide to
ADDITIONAL COMPENSATION sponsors. financial advisors.
RECEIVED BY WELLS FARGO Although training and education It is important for you to understand that
ADVISORS FROM ETP PRODUCT compensation is not related to individual almost every fund that is sold by Wells Fargo
transactions or assets held in client accounts, Advisors provides some degree of
SPONSORS it is important to understand that, due to the educational and training reimbursement to
In addition to the transaction based total number of product sponsors whose Wells Fargo Advisors and its financial
commissions received by Wells Fargo products are offered by Wells Fargo advisors. For example, if you attend training
Advisors and your financial advisor, Wells Advisors, it is not possible for all product or educational meetings with your financial
Fargo Advisors receives certain non- sponsors to participate in a single meeting or advisor and a representative of a product
transaction related payments from ETP event. Consequently, those product sponsors sponsor is in attendance, you should assume
product sponsors, including reimbursements who do participate in training or educational that the product sponsor has paid or

586380 (Rev 38 - 09/22) Page 19 of 21

reimbursed Wells Fargo Advisors for part or If you have questions about any product or
all of the total costs of the meeting or event. service offered or what role your financial
advisor or any other Wells Fargo team
Wells Fargo Advisors offers a wide variety of member is serving, or what compensation is
ETPs for our financial advisors to sell or being paid with respect to any product or
recommend, including funds that do not service, please ask your relationship
compensate Wells Fargo Advisors for any or manager or financial advisor.
all of the services above. Such is not a
prerequisite for a fund to be made available Wells Fargo Advisors has an incentive to
through Wells Fargo Advisors. make available the product providing us with
the higher compensation. Mutual funds
AFFILIATE RELATIONSHIPS typically pay additional compensation to us
WITH ETP COMPANIES that ETPs do not. When certain mutual funds
and ETPs are comparable with respect to
Wells Fargo & Company (Wells Fargo), one investment strategy or similar in other
of the largest financial holding companies in respects, the difference in financial
the United States, provides a wide range of arrangements between ETPs and mutual
financial services through its subsidiaries and funds creates a conflict of interest in that we
affiliates, including Wells Fargo Advisors. have an incentive to make only the mutual
These other relationships provide financial fund and not the similarly situated ETP
and other benefits to Wells Fargo as well as available to you, even though the comparable
Wells Fargo Advisors. These relationships ETP may be less expensive for you.
include the following services:
Before buying any ETP, it is important for you
• Wells Fargo, through its affiliates, licenses to read and understand the ETP’s
indices to ETP sponsors and receives prospectus. If you have any questions about
licensing compensation from the sponsors. a specific ETP, or the information in the
ETP’s prospectus, contact your financial
Within the division that operates in Wells
advisor. Additionally, to learn more about
Fargo Bank financial centers and Wells Fargo
ETPs in general, contact your financial
branches, financial advisors can assist you
advisor or visit the following websites:
with your ETP investment needs. A licensed
banker is a Wells Fargo Bank associate who Wells Fargo Advisors:
is registered with Wells Fargo Advisors.
www.wellsfargoadvisors.com
Licensed bankers may refer you to a financial
advisor. In these instances, the financial Investment Company Institute:
advisor and licensed banker may be
compensated for the sale of an ETP. www.ici.org
Referrals and recommendations are made
independent of compensation arrangements Financial Industry Regulatory Authority:
and based solely on the client’s needs and www.finra.org
objectives.
Securities and Exchange Commission:
YOUR RELATIONSHIP WITH www.sec.gov
WELLS FARGO & COMPANY
Wells Fargo & Company appreciates your
confidence and wants to make your
brokerage and banking relationships clear
and convenient for you. Your Wells Fargo
Advisors financial advisor may serve as your
relationship manager not only for your
brokerage accounts and services with Wells
Fargo Advisors, but also for products and
services with Wells Fargo Bank, N.A.,
including trust accounts of which you may be
a beneficiary or agency accounts in which
you may have an interest.
The responsibilities of Wells Fargo Advisors
and your financial advisor, when acting in a
brokerage or investment advisory capacity or
in introducing you to a banking product or
service, are different from the responsibilities
of Wells Fargo Bank and your financial
advisor when acting in a role as relationship
manager for a Wells Fargo Bank trust or
agency account. Your financial advisor, in a
brokerage or investment advisory capacity,
may recommend or assist you with a
transaction that does not concern the Wells
Fargo Bank trust or agency account for which
he or she will be compensated. If you decide
to enter into such a transaction, you will
receive specific disclosures in connection
with the transaction, including all relevant
information and a description of the
compensation that your financial advisor will
receive. You will have the opportunity to ask
for more information about the compensation
to your financial advisor on such a
transaction.

586380 (Rev 38 - 09/22) Page 20 of 21

 In the unlikely event of a citywide or regional
4. BUSINESS CONTINUITY disruption, WFCS has established recovery
The following information concerns Wells sites approximately 150 miles from the
Fargo Clearing Services, LLC's (WFCS) Richmond area and 28 miles from its St.
efforts to ensure that impact to your business Louis headquarters that can be used to
is minimized in the event of an emergency or restore time sensitive functions as soon as
disaster. key employees are relocated to the facility.
Additionally, as a subsidiary of Wells Fargo &
Securities industry regulations require each Company, WFCS would intend to take
member firm to create and maintain a advantage of any available facilities of other
business continuity plan designed to meet its Wells Fargo & Company affiliates that may
obligations to its clients or other counter- be located in other geographic regions. In the
parties. In accordance with these event that any such disruption occurs, we
requirements, WFCS has designed a have developed alternative service
business continuity plan to address possible arrangements, systems, locations, and
scenarios in efforts to minimize any service contingency plans to ensure that any service
impact to our introducing firms or their clients. affected is quickly restored.
In keeping with the regulatory requirements, WFCS has identified several computer
the business continuity plan for WFCS is applications with Mission Critical or High
designed to address key areas of concern- criticality ratings and has documented this
including, but not limited to, the following: within the business continuity plans. Our
primary application provider, Thomson
• Data backup and recovery; Transaction Services, Inc., has conducted
• Mission-critical systems; successful testing with WFCS, generally two
times per year since November 2000. Finally,
• Financial and operational assessments;
through its parent company, WFCS utilizes
• Alternate means of communication data centers, located in other states, which
between WFCS and its clients; regularly perform disaster recovery testing.
• Alternate means of communication At a minimum, the WFCS business continuity
between WFCS and its employees; plan is reviewed, updated, and tested on an
• Alternate physical locations of employees; annual basis. Additionally, our primary
internal and external application providers
• Critical business constituent, bank and periodically conduct testing of their own back-
counter-party impact; up capabilities to ensure that, in the event of
• Regulatory reporting; an emergency or significant business
disruption, they will be able to provide us with
• Communications with regulators; and the critical information and applications we
• How WFCS will ensure that clients have need to continue or promptly resume our
access to their funds and securities in the business. When testing our plan, we review
unlikely event WFCS determines it is the recovery time and resumption time period
unable to continue its business. for all mission critical systems.
Since events creating disruption of business Making sure that any type of disruption does
may vary in nature and scope, WFCS has not unduly affect our introducing firms or their
anticipated scenarios in which the following clients is extremely important to us, and our
are affected: business continuity plan is designed to allow
us to continue to provide the quality service
• A primary WFCS building at its you have come to expect from WFCS.
headquarters location
• A WFCS branch location
• A citywide area
• A regional area
Regardless of the scope of potential
disruption, WFCS intends to continue to
provide service to its introducing firms and
their clients. In the event where a primary
building or business district is affected, the
firm is fortunate to have a divided corporate
presence in the Richmond, Va. and St. Louis,
Mo. areas. The facilities in both areas are
also served by UPS systems and have 24-
hour security services. Should one of the
primary buildings in Richmond or St. Louis be
affected by a disruption, alternate facilities
exist in each area that can be used to help
restore operations.

Throughout this guide the word ''guarantee'' refers to guarantees backed by the claims-paying ability of the issuing insurance company. If the
insurance company is unable to meet the claims, the payments may not be made. Annuities are available through insurance subsidiaries of Wells
Fargo & Company and insurance underwriters. Not available in all states. Annuities are long-term investments suitable for retirement funding and
are subject to market fluctuations and investment risk. Fees are charged to pay for death benefits and other riders guaranteed by the issuing
insurance company. Withdrawals from an annuity before age 59½ may incur a 10 percent tax penalty in addition to ordinary income tax. The
prospectus on a variable annuity contains more complete information, including fees and expenses. Please read it carefully before investing. Wells
Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC, a registered broker-dealer and non-bank affiliate of Wells Fargo &
Company.

586380 (Rev 38 - 09/22) Page 21 of 21

WellsTrade Account Commissions
and Fee Schedule
Effective September 3, 2022

2022 Account Commissions and Margin Rates of Interest

WellsTrade Account Commissions1
Stocks and Exchange-Traded Funds (ETFs)
Online or Automated Telephone Trading Agent-assisted Trading
$0 $25
Penny Stocks (stocks priced at less than $1.00/share)
Online or Automated Telephone Trading Agent-assisted Trading
Greater of $34.95 or 3.5% of principal $25 + Online trading commission
Mutual Funds2, 3, 9
Transaction Type Online, Automated Telephone Trading, or Agent-assisted Trading
No-Load No-Transaction Fee (NTF) Funds $0
No-Load Transaction Fee Funds $35
Load Funds Refer to prospectus
Options
Online or Automated Telephone Trading Agent-assisted Trading
$5.95 + $0.75 per contract $25 + Online trading commission
Options exercises and assignments
Agent-assisted stock commission
Fixed Income

Auction of Treasury Bills, Notes and Bonds $50 per transaction All other transactions are subject to
markup or markdown.

Margin Rates
Margin Debit Rate of Interest Household Assets Adjuster
Balance Under Management
<$25K WSJ Prime + 5.75% Less than $250,000 0%
$25K < $50K WSJ Prime + 5.25% $250,000 to $499,999.99 -0.5%
$50K < $100K WSJ Prime + 4.75% $500,000 to $999,999.99 -1.0%
$100K < $250K WSJ Prime + 4.25% $1,000,000 to $2,499,999.99 -1.5%
$250K < $500K WSJ Prime + 3.75% $2,500,000 to $4,999,999.99 -2.0%
$500K < $1MM WSJ Prime + 3.25% $5,000,000 and up -2.5%
$1MM < $5MM WSJ Prime + 2.75% For the WSJ Prime Rate, please visit: https://www.wsj.com/
$5MM < $10MM WSJ Prime + 2.25% market-data/bonds/moneyrates.

>$10MM WSJ Prime + 1.75%

Unpaid cash account WSJ Prime plus 5.75%, regardless of debit size or
balances household assets under management

The interest rate charged to you may be individually negotiated instead of based on the standard table of interest rates (a
"Negotiated Rate"). At the time any Negotiated Rate is established for your account, we will notify you of the expiration date, if
any, to your Negotiated Rate. After the expiration date, if any, we may change your Negotiated Rate without giving you any
prior notice of the change. We may charge a different (i.e., higher or lower) interest rate based on factors determined by us, at
our sole discretion, including, but not limited to, account activity or your overall business relationship with us.

Investment and Insurance Products are:

• Not Insured by the FDIC or Any Federal Government Agency
• Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate
• Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested
Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC (WFCS), Member SIPC, a registered broker-dealer and
non-bank affiliate of Wells Fargo & Company. WellsTrade brokerage accounts are offered through WFCS.

586358 (Rev 28 - 09/22) Page 1 of 4

2022 WellsTrade Account Commissions and Fee Schedule
Page 2 of 4

• Interest is computed daily.

• Payments for purchases in cash accounts should be received on or before the settlement date of the trade. If
your payment is received after that date, interest may be charged to your account at the WSJ Prime Rate plus
5.75%. Disbursement for a sale in a cash account is not required to be made prior to the settlement date of the
trade. Occasionally, we may honor your request to receive payment of the sale proceeds prior to settlement
date. If so, an interest charge may be posted to your account, calculated at the prevailing margin interest rate
and subject to a minimum dollar amount.
• Margin borrowing adds risk to your investments and is not suitable for all investors. Market conditions can
magnify any potential for loss. If the market value of the eligible securities in your margin account declines, you
may be required to deposit more money or securities in order to meet minimum equity requirements. In
accordance with the terms and conditions of your margin agreement, we may be forced to sell securities held in
your account, without notice to you, whether or not a call has been issued. The agreement also stipulates that
margin-lending policies may be changed at any time.

Please review the chart below for a list of fees. Clients will pay a single annual fee per WellsTrade® household. Annual fees will
be charged in September 2022 and will be based on the WellsTrade account(s) you hold in your household on June 30, 2022.
We are making it easy for you to have your WellsTrade Household Annual Fee waived (see footnote 4 for details).

Account/Service Fee Amount Frequency

Account Maintenance
Account Research/Document Retrieval $15 per hour Per request
$5 per document (minimum one-hour charge)
Annual Household Fee
Household holding non fee-exempt taxable account $30 Annually4
Outgoing Account Transfer $95 Per transfer
Retirement Account Fees
IRA Custodial Fee $30 Annually5
IRA Termination Fee $95 Per termination6
Trading Fees

No-Load Mutual Fund Transaction Fees3

Online Transaction $35 Per transaction
Agent-assisted transaction $35 Per transaction
Foreign financial transaction fee Variable Per transaction7
SEC Fee Variable Per transaction8
Option Regulatory Fee Variable Per transaction10
U.S. Treasury Auctions $50 Per transaction
Cash Management Services
Deposited/cashed item chargeback $12 Per chargeback
Overnight delivery of checks from Margin Dept. $15 Per delivery11
Unsettled trade prepayment fee A minimum of $10 for amounts up to $50,000 and an Per request12
additional $10 for each $50,000 distributed.
Wire Transfer Fees
Outgoing domestic $30 Per wire request initiated by Wells Fargo team member on behalf of
the client. $0 fee for online wires initiated by the client.
Outgoing international $40 Per wire request initiated by Wells Fargo team member on behalf of
the client. $0 fee for online wires initiated by the client.
Investment Specific
American/Global depositary receipt fee pass-through Varies per security Per occurrence13
Deposit/withdrawal at custodian $250 for outbound transactions Per occurrence14
Outside investment $250 Annually, per security15
UBTI 990-T Tax Filing $200 Per return16
Physical Securities Fees
Safekeeping fee $150 Annually, per security17
Physical certificate issuance/presentment for $500 (minimum) One-time, per security
safekeeping
Rejection of ineligible certificates presented for $75 Per rejection
deposit
Replace certificate lost by client $100 plus out-of-pocket expenses Per occurrence

586358 (Rev 28 - 09/22)

2022 WellsTrade Account Commissions and Fee Schedule
Page 3 of 4

1. Each trade order will be treated as a separate transaction 5. Households comprised only of IRA accounts will be
subject to commission. An order that executes over subject to a $30 IRA Custodial Fee. Households with an
multiple trading days may be subject to additional IRA and any other account type that is not exempt from
commission. One commission will be assessed for annual fee will be subject to the $30 Household Annual
multiple trades, entered separately, that execute on the Fee. IRA Custodial Fee will be waived for households
same day, on the same side of the market. paying a household annual fee. If an IRA Custodial Fee is
due, clients will receive a remittance notice with several
2. Wells Fargo Advisors receives remuneration from fund
payment options. If a payment option is not selected, the
company complexes, including but not limited to:
fee will be automatically deducted from the IRA in
networking and omnibus service fees; revenue sharing;
September 2022. If there is more than one non-exempt
intra-company compensation arrangements; training and
IRA in the household, the fee will be equally divided
education support; and other compensation for general
among the non-exempt IRAs. The grouping of accounts
services provided to the funds. Please see the Guide to
into a household is based on account eligibility and family
Investing in Mutual Funds for more information at
relationship such as children, parents, domestic partners,
www.wfa.com/mutualfundguide.
and others. Certain accounts cannot be included in a
3. For load funds, refer to the prospectus for the fund's household. Please call us at 1-800-TRADERS for more
annual operating expenses which include management, information and to determine whether all eligible
marketing and distribution fees as well as other expenses accounts have been included in your household. It is your
such as administrative services. responsibility to ensure that all eligible accounts are
No-load mutual funds are funds that do not charge a included in your household. Note: In the event that an
sales load when you buy or sell the funds. A transaction annual fee results in a debit balance in the account, Wells
fee is a trading fee that is charged by the brokerage firm Fargo Advisors may liquidate securities in the account to
when you buy or sell shares of a fund, and may be satisfy the debit, without prior notification to the client.
avoided by buying or selling directly from the fund 6. Termination fee applies to full distribution of Traditional,
company. All mutual funds, including "no load" funds, Roth, SEP, and SIMPLE IRAs; fee is waived for clients
incur transaction costs, expenses, and other fees that are over age 70½ or accounts terminated due to death or
passed through by the mutual fund to fund shareholders. disability.
Costs and other expenses apply to a continued
7. Some foreign governments impose a fee on purchases
investment in a mutual fund and are described in the
and sales of securities for companies incorporated in their
fund's current prospectus.
countries. This fee is passed through from the foreign
4. The $30 Household Annual Fee or the IRA Custodial Fee government to the client. If this fee is charged, the
(for IRA only households) can be waived with one of the amount will be displayed on the trade confirmation.
following for all WellsTrade accounts in your household as
8. The Securities and Exchange Commission (SEC) charges
of June 30: a) electronic delivery only enrollment for
us a fee (Section 31 Fee) on all sales of securities and
statements, trade confirmations, other documents, and
securities futures transactions with the exception of index
shareholder communications (excluding tax
options that deliver cash. Wells Fargo Advisors passes
documents/1099s), b) linkage to a Wells Fargo Prime
these fees through to you and the fees will be displayed
Checking, Premier Checking, or Private Bank Interest
on the trade confirmation. The SEC sets the Section 31
Checking account, c) household balances of $250,000 or
Fee rate as a dollar amount per $1 million of securities
more, d) households with solely SEP IRA, or e) Wells
traded. The SEC periodically announces changes to the
Fargo Private Bank clients. If a Household Annual Fee is
rate of the Section 31 Fee in a press release titled "Fee
due, the highest-value account in the client’s household
Rate Advisory" for the particular fiscal year. More
that is eligible to be charged a fee will be debited in
information the Section 31 Fee can be found in the Press
September of each year. The grouping of accounts into a
Releases section of the SEC website.
household is based on account eligibility and family
relationship such as children, parents, domestic partners, 9. Transaction fee applies per transaction (buy or sell). You
and others. Certain accounts cannot be included in a can choose to buy or sell shares directly from the fund
household. Please call us at 1-800-TRADERS for more itself or its principal underwriter or distributor without
information and to determine whether all eligible paying a fee to Wells Fargo Advisors.
accounts have been included in your household. It is your
10. The Option Regulatory Fee (ORF) is a pass-through
responsibility to ensure that all eligible accounts are
exchange fee collected by the OCC on behalf of the U.S.
included in your household. Note: In the event that an
option exchanges. The ORF is assessed to customer
annual fee results in a debit balance in the account, Wells
orders per the U.S. exchange listed option contract and is
Fargo Advisors may liquidate securities in the account to
assessed on all trades, both buys and sells.
satisfy the debit, without prior notification to the client.
11. Overnight deliveries of checks are subject to an
4b. Refer to the Wells Fargo Bank Consumer Account Fee and
additional convenience charge. If Overnight Delivery of
Information Schedule for further information about the
checks is requested, a fee of $15 will be charged in
Prime Checking account and Premier Checking account
addition to any other charges/fees that may apply.
and applicable bank fees. For The Private Bank Interest
Checking account and applicable bank fees, refer to both 12. A prepayment is a payout (ACH, Checks and Federal
the Wells Fargo Consumer Account Fee and Information Funds Wires) using funds from the proceeds of an
Schedule and The Private Bank Consumer Deposit unsettled sale of securities. These should be limited to
Products Disclosure. Some brokerage accounts are not time-sensitive requests only. The unsettled trade prepay
eligible to be linked to a Prime Checking, Premier fee will be a minimum of $10 for amounts up to $50,000
Checking, or Private Bank Interest Checking account. and an additional $10 for each $50,000 distributed.
These ineligible brokerage accounts will not count toward 13. Agents for foreign securities may impose a fee for
qualifying balance requirements for Prime Checking, custodial services rendered. If this fee is imposed, it will
Premier Checking, or Private Bank Interest Checking, nor be passed to the client.
receive Prime Checking, Premier Checking, or Private
Bank Interest Checking benefits.

586358 (Rev 28 - 09/22)

2022 WellsTrade Account Commissions and Fee Schedule
Page 4 of 4

14. Deposit/withdrawal At custodian is the process of

transferring shares between broker-dealer and the
security issuer's transfer agent. This fee applies only to
transactions delivering shares from Wells Fargo Advisors
to the custodian.
15. Fee applies to any asset for which Wells Fargo Advisors
does not hold a selling agreement but has met the
requirements to be displayed on the client statement.
Applies to outside investments displayed on both
standard brokerage and IRA statements.
16. Wells Fargo Advisors files IRS Form 990-T (Exempt
Organization Business Income Tax Return) on behalf of
custodial retirement accounts with Unrelated Business
Taxable Income (UBTI).
17. All restricted stock, regardless of whether it is eligible to
be held in street name, is subject to the Safekeeping fee.
The fee also applies to unrestricted stock eligible to be
held in street name.

This schedule is subject to change at any time.

586358 (Rev 28 - 09/22)

Cash Sweep Program Disclosure Statement
Summary
Please consult the full text of the disclosure statement below for further information at the pages indicated.
The available sweep options currently consist of 1) interest-bearing deposit accounts at affiliated and
unaffiliated banks (together, the “Program Banks”) in our Expanded Bank Deposit Sweep program, 2)
Available Sweep
interest-bearing deposit accounts at two or more affiliated banks in our Standard Bank Deposit Sweep Page 2
Options program, and 3) one or more non-proprietary Money Market Mutual Funds. Eligibility for each available
sweep vehicle is determined by account type.
How the Cash Through our Cash Sweep Program you may earn a rate of return on the uninvested cash balances in your
Sweep Program account by automatically placing ("sweeping") cash balances into a sweep vehicle until such balances are Page 2
Works invested by you or otherwise needed to satisfy obligations arising in connection with your account.
The rates of return for the sweep options vary over time. Current rates can be obtained from your investment
professional, by calling the general inquiries phone number listed on the front of your account statement, or
found on our website at https://www.wellsfargoadvisors.com/cashsweep.
• The interest rates on the Standard Bank Deposit Sweep and Expanded Bank Deposit Sweep will reflect
the amounts that the Program Banks credit to their respective deposit accounts, net of the fees paid to
Wells Fargo Advisors and others, as set forth below under “Benefits to Wells Fargo Advisors and
Others.” The rates of interest paid on affiliated Program Bank deposits will be periodically set and re-set
by the affiliated Program Banks in consultation with Wells Fargo Advisors. Wells Fargo Advisors will
direct and otherwise cause the unaffiliated Program Banks participating in the Expanded Bank Deposit
Sweep program to credit interest on their respective deposits at the same rate then being credited by the
affiliated Program Banks. With certain exceptions, the rate will be tiered based upon account type and
Rate of Return the overall household value of your account(s) with Wells Fargo Advisors. Page 3
• Money Market Mutual Funds seek to achieve the highest rate of return (less fees and expenses)
consistent with prudence and their investment objectives.
• There is no guarantee that the yield on any particular cash sweep will remain higher than others over any
given period. The rate of return on any of our sweep vehicles may be lower than that of similar
investments offered outside of the Cash Sweep Program.
The Cash Sweep should not be viewed as a long-term investment option. If you desire to maintain cash
balances for other than a short-term period and/or are seeking the highest yields currently available in the
market, please contact your investment professional at the number on your account statement to discuss
investment options that may be available outside of the Cash Sweep Program to help maximize your return
potential consistent with your investment objectives and risk tolerance.
You must monitor and determine the best cash sweep for you under this program. You may also elect not to
Duty to Monitor participate in the Cash Sweep Program and instead periodically invest cash balances directly. Page 3

You will be notified in advance if we modify the Cash Sweep Program in certain respects, including
Changes to the modifications that result in changing the sweep vehicle for your account. Unless you tell us otherwise within
Page 4
Sweep Program the time period specified in the notice, you will be treated as approving the change and your cash balances
will be moved to the new sweep vehicle that we designate under the program.

Benefits to
Wells Fargo Advisors has a financial interest in the Cash Sweep Program. We receive fees and other financial
benefits under the different sweep vehicles. Your investment professional is compensated based on total
assets in your account(s), including assets in the Cash Sweep Program. Because of these fees and benefits, Page 4
Wells Fargo
Advisors we have a financial incentive to offer the particular sweep vehicles included in our Cash Sweep Program.
The available Cash Sweep Program options (currently, Money Market Mutual Funds, the Standard Bank
Deposit Sweep, and the Expanded Bank Deposit Sweep) are subject to different risks and account protection:
• Money Market Mutual Funds in the Cash Sweep Program invest in high quality, short-term securities and
seek to maintain a stable value but are subject to market risks and potential value loss. They are not
bank accounts and not subject to FDIC insurance protection. They are instead covered by SIPC, which Page 5
protects against the custodial risk (and not a decline in market value) when a brokerage firm fails by
Differing Risks replacing missing securities and cash up to a limit of $500,000, of which $250,000 may be cash.
and Account • The Standard Bank Deposit Sweep and Expanded Bank Deposit Sweep are not subject to market risk and
Protection potential value loss but are subject to the risk of a bank's failure. In the unlikely event a bank fails, deposits
at each Program Bank are eligible for FDIC insurance protection up to a limit of $250,000 (including
principal and interest) per depositor in each insurable capacity (e.g., individual or joint). This limit includes
any other deposits you may have at each bank outside of these programs. You are responsible for Page 6
monitoring your bank balances in these programs and the balances in any of your other bank
accounts at the same bank to determine if these, in total, exceed FDIC insurance limits. Monies held
in the Standard Bank Deposit Sweep and Expanded Bank Deposit Sweep are not covered by SIPC.

578326 (Rev 43 - 09/22) Page 1 of 8

Introduction Deposit Sweep for your account unless you you select an ineligible Cash Sweep Vehicle,
elect otherwise. your Cash Sweep Vehicle will be (and any
Under the Wells Fargo Advisors Cash Sweep cash balances will be transferred to) the
Program (the "Cash Sweep Program"), Standard Bank Deposit Sweep Expanded Bank Deposit Sweep if you are
uninvested cash balances in your account The Standard Bank Deposit Sweep is eligible (if not, your Cash Sweep Vehicle will
are automatically swept into interest-bearing available as an alternative to the Expanded be (and any cash balances will be transferred
deposit accounts ("Standard Bank Deposit Bank Deposit Sweep. The Standard Bank to) the Standard Bank Deposit Sweep, or an
Sweep" and “Expanded Bank Deposit Deposit Sweep consists of interest-bearing available Money Market Fund selected by
Sweep”, together the “Bank Deposit Sweep deposit accounts at two or more Program us). If you wish to specify a different Cash
Programs”) or, if available, stable-value Banks affiliated with Wells Fargo Advisors Sweep Vehicle, if available for your account
money market mutual funds ("Money Market ("Affiliated Banks"). The Standard Bank type, you may do so at any time by
Funds"), or such other sweep arrangements Deposit Sweep will provide a minimum of contacting us. Existing balances in your prior
made available to you (collectively "Cash $500,000 in FDIC insurance ($1 million for Cash Sweep Vehicle will be automatically
Sweep Vehicles"), until these balances are joint accounts with two or more owners). transferred to the new Cash Sweep Vehicle
invested by you or otherwise needed to Resource accounts and retirement accounts you select.
satisfy obligations arising in connection with in our discretionary advisory programs are
your account. eligible only for the Standard Bank Deposit How the Cash Sweep Program
Sweep, thus for such accounts the primary Works
Available Cash Sweep Vehicles Cash Sweep Vehicle is the Standard Bank
On each business day available cash
Deposit Sweep.
Expanded Bank Deposit Sweep balances will be automatically swept into the
The Expanded Bank Deposit Sweep is the Money Market Fund Cash Sweep Vehicle for your account.
primary Cash Sweep Vehicle for eligible The Cash Sweep Vehicle for ineligible Shares or cash held in your Cash Sweep
clients. The Expanded Bank Deposit Sweep accounts will be a taxable Money Market Vehicle will be automatically redeemed in
consists of interest bearing deposit accounts Fund. A Money Market Fund is also used order to settle a transaction, serve as
at affiliated and unaffiliated Program Banks. when Program Banks have insufficient collateral for a margin loan or short sale, or
The Expanded Bank Deposit Sweep will capacity to accept Bank Deposit Sweep satisfy any other obligations.
provide up to $250,000 in FDIC insurance per Program deposits. See the section below Timing of Credits - Your Cash Sweep
Program Bank ($500,000 per Program Bank titled, "When There is Not Enough Capacity Vehicle will be credited: (i) in the case of
for joint accounts with two or more owners). at the Program Banks to Accept Deposits in available cash balances resulting from the
As of the date of this Disclosure Statement, the Bank Deposit Sweep." The list of Money proceeds of securities sales, on the
the Expanded Bank Deposit Sweep makes Market Funds used as a Cash Sweep Vehicle settlement date of the securities sale; and (ii)
five Program Banks available, resulting in up is available at in the case of available cash balances
to $1.25 million in available FDIC insurance https://www.wellsfargoadvisors.com/cashsweep
resulting from non-trade-related credits (i.e.,
($2.5 million for joint accounts with two or or by contacting your Financial Advisor.
the receipt of dividends, interest payments, or
more owners). You may, at any time, elect to
Among the Money Market Funds offered in deposits), on the business day after receipt
exclude the unaffiliated Program Banks from
the Cash Sweep Program include those by Wells Fargo Advisors of the non-trade-
the Expanded Bank Deposit Sweep. If you
advised by Allspring Global Investments, a related credit (unless there is a trade-related
make this election, you will be in the
money management firm in which Wells debit item pending in your account due to
Standard Bank Deposit Sweep and only two
Fargo holds a small ownership interest (less settle in one business day, in which case only
Affiliated Banks will receive your uninvested
than 10%) but which is not considered an that amount exceeding the trade-related debit
cash. You may not designate that Affiliated
affiliate of Wells Fargo. Prior to, or at the will be credited to your Cash Sweep Vehicle).
Banks be excluded from the Expanded Bank
same time your available funds are first Available cash balances will not earn a rate
Deposit Sweep or exclude less than all of the
swept into an available Money Market Fund, of return until swept into your Cash Sweep
unaffiliated Program Banks. Electing to
you will be furnished with the appropriate Vehicle.
exclude the unaffiliated Program Banks will
result in your uninvested cash not being prospectus, which should be read carefully. Timing of Debits - Your Cash Sweep
deposited into those banks or, if already Mutual fund companies typically offer multiple Vehicle is automatically debited to satisfy
deposited to those banks, we will withdraw share classes with different levels of fees and obligations arising in connection with your
your funds from those banks and deposit the expenses. When selecting the share class for brokerage account, including administrative
funds with the Affiliated Banks in the the Money Market Fund used as a Cash and other fees, and charges in connection
Standard Bank Deposit Sweep. You will have Sweep Vehicle, we do not, in all instances, with a margin account. Cash Sweep Vehicle
less FDIC insurance coverage available if select the share class with the lowest fees balances will also be debited as necessary in
you choose to exclude the unaffiliated that is available from the fund company and connection with certain account activity and
Program Banks and, if you have sweep these decisions are influenced by the services, including securities transactions,
deposits in excess of $500,000 ($1 million for additional compensation we receive in preauthorized electronic transfers, automated
joint accounts) you may have uninsured connection with your account's Money Market payments, checks, or debits from using the
deposits at the Affiliated Banks through the Fund holdings. The use of a more expensive linked debit cards. Your brokerage account
Standard Bank Deposit Sweep. You need to share class of a Money Market Fund as a will be scanned automatically for debit items
contact us if you wish to change to the Cash Sweep Vehicle will negatively impact each day. Debit balances will be satisfied
Standard Bank Deposit Sweep. Eligible your overall investment returns. automatically from: (i) available cash
clients may select the Standard Bank Deposit balances; (ii) funds in any Money Market
Prior to the receipt of your signed account
Sweep at account opening or subsequently at Fund no longer serving as your Cash Sweep
documents, cash deposited into your account
any time after the account is opened. Vehicle; (iii) through the withdrawal of funds
and not otherwise invested will be held as a
Resource accounts and retirement accounts from your Cash Sweep Vehicle; and (iv),
free credit balance and not placed in the
in our discretionary advisory programs are where applicable, from margin loans.
Cash Sweep Program until written consent is
not eligible for the Expanded Bank Deposit
provided to participate in the Cash Sweep Access to Funds - You may only access the
Sweep. By entering in an account agreement
Program. Except for retirement accounts, balances held in your Cash Sweep Vehicle
where the Expanded Bank Deposit Sweep is
while any cash remains in free credit balance, through your brokerage account at Wells
offered, you will be treated as having
you will not earn any interest on such Fargo Advisors. Pursuant to SEC rules,
approved the use of the Expanded Bank
balance. When you open your account, or

578326 (Rev 43 - 09/22) Page 2 of 8

Money Market Funds may impose a fee on exceptions the total household value of contact your investment professional at the
redemptions (liquidity fee) of up to 2% or a assets in your account(s) with Wells Fargo number on your account statement to discuss
suspension of redemptions (gate) if a fund's Advisors such that clients in higher asset tiers investment options that may be available
weekly liquid assets falls below 30% of its will generally receive higher interest rates. outside of the Cash Sweep Program to help
total assets, and if the fund's board considers The total household value will include any maximize your return potential consistent with
such actions in the best interest of the fund's balances in the Bank Deposit Sweep your investment objectives, liquidity needs,
shareholders. In addition, the Money Market Programs, as well as all other assets listed in and risk tolerance. Please note, however,
Funds may reserve the right to require one or your Wells Fargo Advisors account that available cash accumulating in your
more days prior notice before permitting statements, except for those shown under the account will not be automatically swept into
withdrawals. Please refer to the fund's "Other Assets/Liabilities" section. The any investment you purchase outside of the
prospectus for further information. grouping of accounts into a household can be Cash Sweep Program.
performed by your investment professional
Statements and Confirmations - Your based on account eligibility and family Your Responsibility to Monitor
account statement will indicate your balance,
detail transactions, and reflect interest or
relationships. In general, a household may Your Cash Sweep Vehicle
contain all of your personal accounts as well
dividends relating to your Cash Sweep As returns on the Cash Sweep Vehicles, your
as the accounts of your spouse or domestic
Vehicle. These account statements are personal financial circumstances, and other
partner, dependents, and wholly owned
provided in lieu of separate confirmations of factors change, it may be in your financial
businesses. Retirement and Advisory
sweep transactions. interest to change your Cash Sweep Vehicle
accounts in the Bank Deposit Sweep
(if another option is available for your account
Interest/Dividends Payable - Interest on Programs may receive a tier rate that is
type) or invest cash balances in products
cash in the Bank Deposit Sweep Programs is generally higher than that paid to other
offered outside of the Cash Sweep Program
accrued daily, compounded monthly, and account types. Resource accounts in the
consistent with your investment objectives
credited to your account on the last business Standard Bank Deposit Sweep will be tiered
and risk tolerance. Wells Fargo Advisors
day of each monthly statement period. based on the cash balance in the account
does not have any duty to monitor the Cash
Dividends on the shares in the Money Market and household value will have no effect on
Sweep Vehicle for your account or make
Fund will not be payable in cash but will be rates in the Resource account. Tiers and
recommendations about, or changes to, the
reinvested each month in additional shares of interest rates on different tiers may change
Cash Sweep Program that might be
the applicable Money Market Fund at the from time to time at Wells Fargo Advisors'
beneficial to you.
current net asset value. Dividends are not discretion. Please contact your investment
guaranteed and are subject to change or professional at the number on your account Alternatives to the Cash Sweep
elimination. statement to find out more about house
holding and to ensure all eligible accounts Program
Rate of Return are grouped in a household. You may elect not to participate in the Cash
Sweep Program and/or periodically invest
The rate of return for each available Cash Neither Wells Fargo Advisors nor any of the cash balances directly in available money
Sweep Vehicle can be obtained from your Program Banks are under any obligation to market mutual funds or other products
investment professional, by calling the provide the highest rates available in the offered as direct investments outside of the
general inquiries phone number listed on the marketplace. Higher rates may be available Cash Sweep Program by providing
front of your account statement or found on outside of the Cash Sweep Program. By instructions to your investment professional.
our website at making the Cash Sweep Program available, Outside the Cash Sweep Program, you may
https://www.wellsfargoadvisors.com/ Wells Fargo Advisors assumes no obligation also link your account to a bank deposit
cashsweep. to seek or negotiate interest rates in excess account. Your cash balances will be swept to
of any reasonable rate of interest the and from the designated bank account and
These rates will vary over time and may be
affiliated Program Banks are willing to credit. will be used for settlement activity. This
lower than rates available to clients making
In the Bank Deposit Sweep Programs, lower option may be unavailable for some account
deposits directly with the Program Banks or
rates are more financially beneficial to Wells types. Please note if you elect not to
at other banks, or available by
Fargo Advisors and others, including the participate in the Cash Sweep Program, and
investing directly in other money market
Affiliated Banks. By comparison, a Money do not link to your bank account, accruing
mutual funds not offered through the Cash
Market Fund generally seeks to achieve the cash balances will not earn a rate of return
Sweep Program. You will receive the same
highest rate of return (less fees and prior to direct investment. In addition,
interest rate on deposits at the Program
expenses) consistent with the fund’s available cash will not be automatically swept
Banks in the Bank Deposit Sweep Programs.
investment objective, which can be found in into any money market mutual fund or other
The interest rates on the Standard Bank the fund’s prospectus. (Money Market Fund investment that you purchase outside of the
Deposit Sweep and Expanded Bank Deposit rates are, however, affected by the fees Cash Sweep Program.
Sweep can change at any time. The rates of applicable to the particular class of shares
interest paid on affiliated Program Bank made available through the Cash Sweep Your investment professional can provide
deposits will be periodically set and re-set by Program.) As a result, the current rate of further details and additional information,
the affiliated Program Banks in consultation return on each Cash Sweep Vehicle will vary including a prospectus, for any of the money
with Well Fargo Advisors. Wells Fargo over time and there is no guarantee that the market mutual funds available for direct
Advisors will direct and otherwise cause the return on any particular Cash Sweep Vehicle investment outside of the Cash Sweep
unaffiliated Program Banks participating in will remain higher than the others over any Program. Please read the prospectus
the Expanded Bank Deposit Sweep program given period. carefully before investing. Investments in
to credit interest on their respective deposits money market mutual funds are not
The Cash Sweep Vehicle for your account guaranteed or insured by the FDIC or any
at the same rate then being credited by the
should not be viewed as a long-term other government agency and are not
affiliated Program Banks. Wells Fargo
investment option. If you desire, as part of an deposits of a bank or bank affiliate. Although
Advisors and others will receive
investment strategy or otherwise, to maintain retail and U.S. Government money market
compensation from Program Banks in
a cash position in your account for other than mutual funds seek to preserve their net asset
connection with the Cash Sweep Program, as
a short period of time and/or are seeking the value at one dollar per share, it is possible to
set forth below under "Benefits to Wells
highest yields currently available in the lose money by investing in money market
Fargo Advisors and Others." The rate will be
market for your cash balances, please mutual funds.
based upon account type and with certain

578326 (Rev 43 - 09/22) Page 3 of 8

Changes to Cash Sweep Vehicles used as a Cash Sweep Vehicle, we do not, in Under the Expanded Bank Deposit Sweep,
all instances, select the share class with the we pay an unaffiliated third-party
From time to time, Wells Fargo Advisors may
lowest fees that is available from the fund administrator a fee for its services. This fee
modify the Cash Sweep Program, which may
company and these decisions are influenced includes an asset-based fee, which will vary
result in changing the Cash Sweep Vehicle
by the additional compensation we receive in based on deposit balances at the unaffiliated
for your account. If we make any change
connection with your account's Money Market Program Banks. We do not pay the third-
there is no guarantee that such change will
Fund holdings. The use of a more expensive party administrator on deposits held in the
provide an equal or greater rate of return to
share class of a Money Market Fund as a Affiliated Banks. Thus, the profitability of the
you during any given period, and the rate
Cash Sweep Vehicle will negatively impact Expanded Bank Deposit Sweep is based in
of return may be lower. You will receive
your overall investment returns. The Money part on deposit balances, which may be
advance notice of certain changes we may
Market Funds offered include those in which greater depending on the size of the overall
make to the Cash Sweep Program, including
an affiliate of Wells Fargo Advisors has a deposit balances in the Expanded Bank
changes from one Cash Sweep Vehicle to
limited ownership interest and receives Deposit Sweep.
another, any reductions in the number of
compensation for services provided to such
Program Banks in either of the Bank Deposit We and the Program Banks may pay rates of
Money Market Funds.
Sweeps, or, for retirement accounts, any interest on the Expanded Bank Deposit
reprioritization of the Affiliated Banks relative Expanded Bank Deposit Sweep Sweep that are lower than prevailing market
to the unaffiliated Banks under the Expanded Wells Fargo Advisors and its affiliates benefit interest rates. Wells Fargo Advisors has a
Bank Deposit Sweep, if it affects your financially from cash balances held in the conflict of interest because it influences both
account. Unless you object within the time Expanded Bank Deposit Sweep. With respect what it pays you in interest and what it and its
period specified, you will be treated as to the Affiliated Banks, profitability is employees receive in compensation on the
approving the change and Wells Fargo determined in large part by the difference or Expanded Bank Deposit Sweep. This
Advisors will transfer the balances from your "spread" between the interest they pay on compensation is subject to change and we
prior Cash Sweep Vehicle into any new Cash deposits, and the interest or other income may waive all or any part of this
Sweep Vehicle. If the trading activity in your they earn on loans, investments, and other compensation at any time without notice.
account results in a "Pattern Day-Trader" assets. Higher rates of interest than the rates However, as noted, the process is different
designation, you may select an available credited by the Affiliated Banks on Expanded for retirement accounts, including IRAs.
Money Market Fund as your Cash Sweep Bank Deposit Sweep deposits may be Retirement accounts participating in the
Vehicle so the balance can be used towards available outside of the Cash Sweep Expanded Bank Deposit Sweep will receive
the minimum equity trading requirement. If a Program. The participation of the Affiliated the same rate on deposits on unaffiliated
day-trader account uses the Standard or Banks in the Expanded Bank Deposit Sweep Program Banks as is set on Affiliated Banks,
Expanded Bank Deposit Sweep, the balance is expected to increase their respective and the amount of fees received on
will not count towards the minimum equity deposits and, accordingly, overall profits. unaffiliated Program Banks is uniform across
trading requirement. all unaffiliated Program Banks; this feature
With respect to the Unaffiliated Banks under will not be changed without advance notice to
If you decide to enroll in a new product or the Expanded Bank Deposit Sweep Program, you.
service that doesn’t offer your current Cash the financial benefits available to Wells Fargo
Sweep Vehicle, your new Cash Sweep Advisors may differ as between retirement Standard Bank Deposit Sweep
Vehicle will become the Expanded Bank accounts relative and non-retirement Wells Fargo Advisors and its affiliates,
Deposit Sweep if you are eligible (if not, your accounts. For retirement accounts (including including the Affiliated Banks, benefit
Cash Sweep Vehicle will be an available IRAs), each unaffiliated Program Bank in the financially from cash balances held in the
Money Market Fund selected by us) unless Expanded Bank Deposit Sweep program will Standard Bank Deposit Sweep. As with other
you select a different available Cash Sweep pay Wells Fargo Advisors a uniform fee up to depository institutions, the profitability of the
Vehicle. 79% of the Federal Funds Effective Rate of Affiliated Banks is determined in large part by
Benefits to Wells Fargo Advisors the average daily total retirement account the difference or "spread" between the
deposit balances at that unaffiliated Program interest they pay on deposit accounts, such
and Others Bank. Because each unaffiliated Program as the Standard Bank Deposit Sweep, and
Wells Fargo Advisors and its affiliates receive Bank will pay us the same amount on the interest or other income they earn on
fees and benefits for services provided in retirement accounts, we have no incentive to loans, investments and other assets. As
connection with the Cash Sweep Program, make deposits with any particular unaffiliated noted above, higher rates of interest than the
and we may choose to make available the Program Bank. In the case of non-retirement rates credited by the Affiliated Banks on
Cash Sweep Vehicles that are more accounts, each affiliated and unaffiliated Standard Bank Deposit Sweep deposits may
profitable to us and our affiliates than other Program Bank in the Expanded Bank Deposit be available outside of the Cash Sweep
money market mutual funds or bank deposit Sweep Program will pay Wells Fargo Program. The participation of the Affiliated
accounts. Your investment professional is Advisors an amount not to exceed a Banks in the Standard Bank Deposit Sweep
compensated based on total assets in your percentage (equivalent to Federal Funds is expected to increase their respective
account(s), including assets held in the Cash Target plus 30 basis points (0.30%)) of the deposits and, accordingly, overall profits.
Sweep Program. daily total non-retirement deposit balances at
that Program Bank, however the amount of Wells Fargo Advisors, its affiliates, and their
Money Market Funds that fee may vary from one Program Bank to respective employees will receive a financial
Wells Fargo Advisors receives distribution the next. This amount includes our fee and benefit in connection with the Standard Bank
(Rule 12b-1), service fees and other interest payable to participating accounts in Deposit Sweep. Wells Fargo Advisors will
compensation as a result of sweeping the Expanded Bank Deposit Sweep. receive compensation from the Affiliated
available cash into the Money Market Funds. Banks in an amount not to exceed a
These fees, which vary depending on the In addition, the management personnel and percentage (equivalent to Federal Funds
Money Market Fund (and class thereof) used, other employees of Wells Fargo Advisors and Target plus 30 basis points (0.30%) of the
are paid directly by the Money Market Funds its affiliates receive incentive compensation daily total deposit balances at the Affiliated
but ultimately borne by you as a shareholder based in part on assets in Affiliated Banks or Banks. The management personnel and
in the fund. Mutual fund companies typically the profitability of Affiliated Banks in the other employees of Wells Fargo Advisors and
offer multiple share classes with different Expanded Bank Deposit Sweep and their its affiliates receive incentive compensation
levels of fees and expenses. When selecting joint parent company, Wells Fargo & based in part on assets in the Standard Bank
the share class for the Money Market Fund Company. Deposit Sweep or the profitability of the

578326 (Rev 43 - 09/22) Page 4 of 8

Standard Bank Deposit Sweep for the covered by FDIC insurance. Please see the and then any available cash in excess of
Affiliated Banks and their joint parent section entitled FDIC Insurance Coverage $248,000 will be deposited up to $248,000 at
company, Wells Fargo & Company. below. each other Program Bank. Except for
retirement accounts, we will, unless indicated
Wells Fargo Advisors has a conflict of interest
because it influences both what Affiliated
Additional Information otherwise on our public website, generally
give priority to one or more additional
Banks pay you in interest and what it and its Regarding the Bank Deposit Affiliated Banks in the Expanded Bank
employees receive in compensation on the
Standard Bank Deposit Sweep. This
Sweep Programs Deposit Sweep. As a result, except for
retirement accounts, the ordering of the
compensation is subject to change and we sweep is, unless indicated otherwise on our
may waive all or any part of this fee at any
Introduction
public website, generally affiliated Banks first,
time without notice. As a result of the fees The Standard Bank Deposit Sweep consists
and then unaffiliated Program Banks. For
and benefits described above, the Standard of interest-bearing deposit accounts at two or
retirement accounts in the Expanded Bank
Bank Deposit Sweep will be more profitable more Affiliated Banks, each a depository
Deposit Sweep, the ordering of the sweep is
to us than the Expanded Bank Deposit institution regulated by bank regulatory
always Affiliated Banks first, and then
Sweep, which means we will receive a agencies under various federal banking laws
unaffiliated Program Banks. In the Expanded
greater benefit if you select the Standard and regulations. If you have selected the
Bank Deposit Sweep, cash in excess of
Bank Deposit Sweep as your Cash Sweep Standard Bank Deposit Sweep as your Cash
$1,240,000 will be swept to Wells Fargo
Vehicle. Sweep Vehicle, available cash balances in
Bank, N.A. and will be uninsured. Sweep
your account are automatically deposited into
deposit limits are set below the FDIC
Other Benefits to Us the Standard Bank Deposit Sweep.
insurance limits to allow for accrued interest
We shall also receive a benefit by retaining
The Expanded Bank Deposit Sweep consists on the deposit accounts at the Affiliated
any interest earned (generally at the Federal
of interest-bearing deposit accounts at Banks and unaffiliated banks. Deposits for
Funds rate) on cash balances awaiting
affiliated and unaffiliated Program Banks, joint accounts, revocable and irrevocable
disbursement or prior to such balances being
each a depository institution regulated by trust accounts are subject to operational
swept into your Cash Sweep Vehicle.
bank regulatory agencies under various limitations and the amount of FDIC insurance
federal banking laws and regulations. If you coverage afforded may be less than the FDIC
SIPC Insurance insurance coverage available under FDIC
have selected the Expanded Bank Deposit
The Securities Investor Protection Sweep as your Cash Sweep Vehicle, rules.
Corporation ("SIPC") protects customers of available cash balances in your account are
its members against the custodial risk to For single, custodial, and IRA and ESA
automatically deposited into the Expanded
clients of securities brokerage firms like Wells accounts, any deposits in the Standard Bank
Bank Deposit Sweep.
Fargo Advisors in the event such firms Deposit Sweep that exceed $496,000 (when
become insolvent. Unlike FDIC insurance, two Affiliated Banks are used) will be
Deposits
SIPC does not insure against the failure of a deposited at Wells Fargo Bank, N.A. and will
security, the quality of investments, or In the Standard Bank Deposit Sweep, the not be FDIC insured. In the Expanded Bank
declines in the value of investments. Instead, uninvested cash balances in your brokerage Deposit Sweep, any deposits that exceed
SIPC protects each client's securities (which account will be deposited at one or more $1,240,000 will be deposited at Wells Fargo
include Money Market Funds) and cash held bank deposit accounts maintained at the Bank, N.A. and will not be FDIC insured.
in a client's brokerage account at an insolvent Affiliated Banks. In the Expanded Bank
Deposit Sweep, the uninvested cash For joint accounts, the Bank Deposit Sweep
brokerage firm by replacing missing
balances in your brokerage account will be Programs can recognize accounts with only
securities and cash up to $500,000 (limited to
deposited at one or more bank deposit two joint owners. As a result, in the Standard
$250,000 for cash) in brokerage accounts
accounts maintained at the affiliated and Bank Deposit Sweep, deposits for joint
held in each separate ownership capacity
unaffiliated Program Banks, although we accounts, regardless of the number of joint
(e.g., individual, joint, trust, retirement) in
generally will give priority to the Affiliated owners, will generally be made only up to
accordance with SIPC rules. Multiple
Banks. In the Bank Deposit Sweep Programs $496,000 initially at Wells Fargo Bank, N.A.
accounts held in the same capacity are
no evidence of ownership, such as a and then any available cash in excess of
aggregated under SIPC. In addition to SIPC,
passbook or certificate, will be issued to you $496,000 will be deposited at each additional
Wells Fargo Advisors maintains a program of
and deposits in the Bank Deposit Sweep Affiliated Bank, up to $496,000 per Affiliated
additional insurance coverage, at no cost to
Programs may be made in the name of Wells Bank. Cash in excess of $992,000 (when two
you, through London Underwriters (led by
Fargo Advisors (or its agents) for the benefit Affiliated Banks are used) will be swept to
Lloyd's of London Syndicates), referred to
of its clients. However, your brokerage Wells Fargo Bank, N.A. and may be
here as "Lloyd's." For clients who have
account statement will reflect all deposits, uninsured. In the Expanded Bank Deposit
received the full SIPC payout limit, Wells
withdrawals, Program Bank deposit Sweep, deposits from joint accounts,
Fargo Advisors’ policy with Lloyd's provides
balance(s), and applicable interest rate. regardless of the number of joint owners, will,
additional coverage above the SIPC limits for
unless indicated otherwise on our public
any missing securities and cash in client In the Standard Bank Deposit Sweep, website, generally be made only up to
brokerage accounts up to a firm aggregate deposits from each account will generally be $496,000 initially at Wells Fargo Bank, N.A.
limit of $1 billion (including up to $1.9 million made initially at Wells Fargo Bank, N.A. up to and then any available cash in excess of
for cash per client). This account protection $248,000, and then any available cash in $496,000 will be deposited up to $496,000 at
package does not cover losses resulting from excess of $248,000 will be deposited at one each other Program Bank, which may include
declines in the market value of your or more additional Affiliated Banks. In the one or more additional Affiliated Banks. We
investments. For more information on SIPC Standard Bank Deposit Sweep, cash in will, unless indicated otherwise on our public
coverage, please see the explanatory excess of $496,000 (when two Affiliated website, generally give priority to any
brochure at www.sipc.org or call Banks are used) will be swept to Wells Fargo additional Affiliated Banks in the Expanded
202-371-8300. For more information about Bank, N.A. and will be uninsured. In the Bank Deposit Sweep. Any deposits that
Lloyd's, please visit www.lloyds.com. Expanded Bank Deposit Sweep, except for exceed $2,480,000 will be deposited at Wells
retirement accounts, deposits from each Fargo Bank, N.A. and may not be FDIC
Since monies in the Bank Deposit Sweep
account will, unless indicated otherwise on insured.
Programs are held at banks, they are NOT
our public website, generally be made initially
covered by SIPC or Lloyd's. They are instead
at Wells Fargo Bank, N.A. up to $248,000,

578326 (Rev 43 - 09/22) Page 5 of 8

The Bank Deposit Sweep Programs cannot retirement or investment advisory accounts. FDIC Insurance Coverage
recognize joint accounts of international Our ability to sweep your uninvested cash to
Balances on deposit in the Bank Deposit
clients. As a result, joint accounts of a Program Bank depends on the Program
Sweep Programs, together with any other of
international clients will be treated like single Bank's capacity to accept the deposits. If a
your deposits at the Program Banks, are
accounts rather than joint accounts. Program Bank has insufficient capacity to
insured by the FDIC, an independent agency
accept additional sweep deposits, or
For revocable and irrevocable trust accounts of the U.S. government, up to a maximum
otherwise reduces its capacity to accept
in the Bank Deposit Sweep Programs, amount in accordance with the rules of the
sweep deposits, and we believe that
regardless of the number of owners and FDIC. Deposits (including principal and
sweeping additional deposits to any other
beneficiaries, deposits are, unless indicated interest) at each of the Program Banks are
Program Bank is unfeasible, some or all of
otherwise on our public website, generally eligible for federal deposit insurance up to
your sweep deposits that exceed current
made initially only up to $248,000 at Wells $250,000. Different ownership categories of
FDIC insurance limits will automatically be
Fargo Bank, N.A. In the Standard Bank accounts are separately insured. Please see
invested in shares of a Money Market Fund,
Deposit Sweep, any available cash in excess the "Deposit Insurance - General Information"
which may be affiliated with us. Purchases of
of $248,000 will be deposited at one or more section below for further information.
shares of the Money Market Fund will be
additional Affiliated Banks. Cash in excess of made within one business day after new If you have other deposits at the Program
$496,000 (when two Affiliated Banks are uninvested cash balances are in your Banks outside of the Bank Deposit Sweep
used) will be swept to Wells Fargo Bank, N.A. account at the then current net asset value of Programs, you must aggregate all such
and may be uninsured. In the Expanded the Money Market Fund. For impacted deposits with your Bank Deposit Sweep
Bank Deposit Sweep, any available cash in accounts, new cash balances will be invested Program balance for purposes of determining
excess of $248,000 will be deposited up to in the Money Market Fund until we determine FDIC coverage. If your total funds on deposit
$248,000 at each other Program Bank. We that sufficient aggregate capacity exists in at any Program Bank exceed the applicable
will, unless indicated otherwise on our public Program Banks to accept all of the then FDIC insurance limit, the FDIC will not insure
website, generally give priority to any current balances swept to the Money Market your funds in excess of the limit. Please note
additional Affiliated Bank in the Expanded Mutual Fund, as well as any uninvested cash that you, and not Wells Fargo Advisors,
Bank Deposit Sweep. Any deposits that in your account, and anticipated future cash are responsible for monitoring the total
exceed $1,240,000 will be deposited at Wells sweep deposits. At that time, new uninvested amount of your deposits at the Program
Fargo Bank, N.A. and may not be FDIC cash in your account will be deposited with Banks in order to determine the extent of
insured. one or more Program Banks and, upon prior FDIC insurance coverage available. If you
Cash intended for deposit into the Bank notice to you, shares in the Money Market expect to have total deposits at the
Deposit Sweep Programs must be deposited Fund will be liquidated and the cash Program Banks, including balances
through your brokerage account and cannot proceeds will be swept to one or more of the through the Standard Bank Deposit
be placed directly by you into a Program Program Banks. Which Program Banks will Sweep or Expanded Bank Deposit Sweep,
Bank. Only balances transferred by Wells receive the deposits will depend on whether that exceed FDIC insurance coverage
Fargo Advisors will be eligible for inclusion in you are in the Standard or the Expanded limits, you should carefully consider
the Bank Deposit Sweep Programs. Deposits Bank Deposit Sweep. whether you should arrange for the direct
by you into Program Banks, outside of the investment of amounts exceeding such
Prior to, or at the same time your available
Bank Deposit Sweep Programs, may coverage.
funds are first swept into a Money Market
adversely affect the FDIC coverage of your Fund for this purpose, you will be furnished In the event that federal deposit insurance
funds. with the appropriate prospectus, which payments become necessary, payments of
should be read carefully. The Money Market principal plus unpaid and accrued interest will
Withdrawals Fund used as a Cash Sweep Vehicle for this be made to you by the FDIC. However, there
Monies on deposit at the Program Banks will purpose is available at is no specific time period during which the
be automatically withdrawn from the bank https://www.wellsfargoadvisors.com/cashsweep FDIC must make insurance payments
deposit accounts in the event of a debit in or by contacting your Financial Advisor. available. Furthermore, you may be required
your Wells Fargo Advisors account or, on to provide certain documentation to the FDIC
settlement date, to pay for securities If neither the Program Banks nor the Money
before insurance payments are made.
purchased for or sold to your Wells Fargo Market Fund have sufficient capacity to
Advisors account. Debits may also be accept additional deposits or investments, If you have additional questions about FDIC
created by writing a check on your Wells your uninvested cash will be held in your insurance, please contact your investment
Fargo Advisors account, making payments brokerage account and earn interest professional at the number on your account
via online bill payment service, withdrawing equivalent to the lowest tier rate paid on the statement. You may wish to seek advice from
funds through your debit card, or to pay other Bank Deposit Sweep. When sufficient your own attorney concerning FDIC
liabilities owed to Wells Fargo Advisors. aggregate capacity in the Program Banks has insurance coverage of deposits held in more
Checks, ACH payments, debit cards, ATM been restored, we will sweep the uninvested than one capacity. You may also obtain
withdrawals, direct deposits, credits, and cash in your account to one or more of the publicly available information by contacting
other transactions and items for your Wells Program Banks. Which Program Banks will the FDIC, Office of Consumer Affairs, by
Fargo Advisors account are processed receive the deposits will depend on whether letter (550 17th Street, N.W., Washington,
through that account rather than through the you are in the Standard or the Expanded D.C. 20429), by phone (877-275-3342 or
bank deposit accounts. Wells Fargo Advisors Bank Deposit Sweep. 800-925-4618 (TDD)), or by accessing the
will debit and credit your bank deposits to FDIC website at www.fdic.gov.
During times when you have sweep
accommodate this processing.
investments in the Money Market Fund or
uninvested cash in your account, and you
Differences between the Bank
When There is Not Enough Deposit Sweep Programs and
use cash in your account, it will first be
Capacity at the Program Banks to deducted from the uninvested cash balance Money Market Funds
Accept Deposits in the Bank in your account, then redeemed from the The Money Market Funds available as Cash
Deposit Sweep Program sweep investment in the Money Market Fund, Sweep Vehicles are registered with the SEC
The information in this section does not apply and finally withdrawn from your balances in pursuant to the Investment Company Act of
to the Bank Deposit Sweep Program for Program Banks, as applicable. 1940. The Bank Deposit Sweep Programs

578326 (Rev 43 - 09/22) Page 6 of 8

consist of interest-bearing deposit accounts banking laws and regulations. The Affiliated accounts with the Program Banks and will not
at the Program Banks, each regulated by Banks are wholly owned subsidiaries of automatically withdraw funds from your
bank regulatory agencies under various Wells Fargo & Company, the fourth largest accounts with the Program Banks to satisfy
federal banking laws and regulations. bank holding company in the United States debits in your brokerage account.
Deposits in the Bank Deposit Sweep based on assets. Wells Fargo Advisors is a
Programs are eligible for FDIC insurance as nonbank affiliate of the Affiliated Banks and Deposit Insurance - General
described above. The retail and U.S. Wells Fargo & Company. Additional
Government Money Market Funds purchase information regarding the Affiliated Banks Information
high quality, short-term securities in seeking and Wells Fargo & Company is available at
to maintain their net asset value of one dollar www.wellsfargo.com. The list of Program General Information
per share. A stable net asset value is not Banks is available at Each Program Bank is insured by the FDIC,
guaranteed and you could experience a loss https://www.wellsfargoadvisors.com/cashsweep an independent agency of the U.S.
of principal investing in these Money Market or by contacting your Financial Advisor.
government, up to a maximum amount of
Funds. Funds invested in a Money Market Deposits in the Bank Deposit Sweep $250,000 (including principal and accrued
Fund are not guaranteed or insured by the Programs are obligations of each Program interest) per depositor in each insurable
FDIC or any other government agency and Bank where the monies are deposited and capacity (e.g., individual or joint) at each
are not deposits of a bank or bank affiliate, are not obligations of, or guaranteed by, Program Bank when aggregated with all
including the Program Banks. Although Wells Fargo & Company or any of its other other deposits held by you at the same
Money Market Funds seek to preserve the affiliates, including Wells Fargo Advisors. Program Bank in the same capacity. Your
value of your investment at $1.00 per share; Neither Wells Fargo & Company nor Wells funds become eligible for deposit insurance
it is possible to lose money investing in a Fargo Advisors guarantees in any way the immediately upon placement in the Standard
Money Market Fund. financial condition of the Program Banks, nor Bank Deposit Sweep or Expanded Bank
are they responsible for any insured or Sweep.
Changes to Program Banks
uninsured portion of any deposits with the In the unlikely event that federal deposit
Wells Fargo Advisors may from time to time
Program Banks. insurance payments become necessary,
announce changes to the Bank Deposit
Sweep Programs that include adding, payments of principal plus unpaid and
Relationship with Wells Fargo
deleting, replacing or changing the sequence accrued interest will be made to you. There is
Advisors no specific time period during which the FDIC
of Program Banks, which may result in
increasing or decreasing the overall FDIC Wells Fargo Advisors will act as your agent in must make insurance payments available.
insurance available through the Bank Deposit establishing and maintaining the Bank Furthermore, you may be required to provide
Sweep Programs. In the event of certain Deposit Sweep Programs, including making certain documentation to the FDIC and Wells
changes, including changes from one Cash deposits to and withdrawals from the Bank Fargo Advisors before insurance payments
Sweep Vehicle to another, any reductions in Deposit Sweep Programs. Your first deposit are made. For example, if you hold deposits
the number of Program Banks in either of the into the Standard Bank Deposit Sweep or as trustee for the benefit of trust participants,
Bank Deposit Sweeps or, for retirement Expanded Bank Deposit Sweep will you may be required to furnish affidavits and
accounts, any re-prioritization of the Affiliated constitute your appointment of Wells Fargo provide indemnities regarding an insurance
Banks relative to the unaffiliated Banks under Advisors as your agent in connection with the payment.
the Expanded Bank Deposit Sweep, you will Standard Bank Deposit Sweep or Expanded
Bank Sweep. No evidence of ownership, The application of FDIC insurance coverage
be notified in advance of the change if it
such as a passbook or certificate, will be limits by account type is illustrated by several
affects your account. If you object to a
issued to you and deposits in the Standard common factual situations discussed below.
change we announce, you may take action
Bank Deposit Sweep or Expanded Bank The illustrations below assume the use of the
within the notice period to discontinue your
Deposit Sweep may be made in the name of Expanded Bank Deposit Sweep. To assist
account's use of the affected sweep option.
Wells Fargo Clearing Services, LLC for the you with calculating your aggregated deposits
Otherwise, you will be deemed to have
benefit of its customers. Accordingly, all and the associated coverage, the FDIC has
provided your consent to the change. If a
transactions involving the Bank Deposit an Electronic Deposit Insurance Estimator
Program Bank no longer makes the Standard
Sweep Programs must be made through available at www.fdic.gov/edie.
Bank Deposit Sweep or Expanded Bank
Deposit Sweep available, you may establish Wells Fargo Advisors and all inquiries relating
Single Accounts - Accounts owned by one
a direct depository relationship with that to the Bank Deposit Sweep Programs should
person, and titled in that person’s name only,
bank, if the bank is accepting such be directed to Wells Fargo Advisors.
are added together and the total insured up
relationships and subject to its policies and If you decide to remove Wells Fargo Advisors to $250,000 at each Program Bank (currently
procedures with respect to maintaining as your agent with respect to the Bank providing a total of up to $1,250,000 when
deposit accounts. If you do not wish to Deposit Sweep Programs, you may establish deposited at all five of the Program Banks).
establish a direct relationship with the bank, a direct depository relationship with a This account category does not include joint
your funds will be transferred to another Program Bank, if the bank is accepting such accounts, certain trusts, and individual
available Program Bank. The consequences relationships, by requesting to have your retirement accounts, which are protected in a
of maintaining a direct depository relationship deposit relationship established in your separate category and discussed below.
with a Program Bank are discussed below name, subject to applicable law and the
under Relationship with Wells Fargo Custodial Accounts - Funds in accounts
Program Bank's terms and conditions. If
Advisors. held by a custodian (for example, under the
Wells Fargo Advisors terminates your use of
Uniform Gifts to Minors Act or the Uniform
Wells Fargo Advisors may notify you of any the Standard Bank Deposit Sweep or
Transfers to Minors Act) are not treated as
of these changes by means of a letter, an Expanded Bank Deposit Sweep, or if you
owned by the custodian, but are added to
entry on your brokerage account statement, choose to remove Wells Fargo Advisors as
other deposits of the minor and insured up to
an entry on a trade confirmation, or by other your agent with respect to the Standard Bank
$250,000 in the aggregate per Program Bank
means. Deposit Sweep or Expanded Bank Deposit
(currently providing a total of up to
Sweep, Wells Fargo Advisors will have no
$1,250,000 when deposited at all five of the
Information about the Program Banks further responsibility for automatically
Program Banks).
The Program Banks are regulated by bank crediting your brokerage account with
regulatory agencies under various federal payments made with respect to your

578326 (Rev 43 - 09/22) Page 7 of 8

Joint Accounts For accounts owned by two
or more people, each person’s share is
insured up to $250,000 separately at each
Program Bank in addition to the $250,000
allowed on other deposits owned individually
in one or more single accounts (currently
providing a total of up to $2,500,000 for
accounts with two joint owners when
deposited at all five of the Program Banks).
The Bank Deposit Sweep Programs can
recognize joint accounts with only two joint
owners.

Revocable Trust Accounts - A revocable

trust account indicates an intention that the
deposit will belong to one or more named
beneficiaries upon the death of the owner(s).
A revocable trust can be terminated at the
discretion of the owner. There are two types
of revocable trusts: informal trusts, known
as Payable on Death (POD) or "Totten
Trusts," and formal trusts, known as "living"
or "family" trusts. Both informal and formal
revocable trusts are insured up to $250,000
per owner for each beneficiary if the FDIC
requirements are met. All deposits that an
owner holds in both informal and formal
revocable trusts are added together for
insurance purposes and the insurance limit is
applied to the combined total. A revocable
trust account established by a husband and
wife that names the husband and wife as sole
beneficiaries will be treated as a joint
account, and will be aggregated with other
joint accounts subject to the rules described
above under "Joint Accounts."

Irrevocable Trust Accounts - Deposits in an

account established pursuant to one or more
irrevocable trust agreements created by the
same person will be insured for up to
$250,000 per Program Bank for the interest
of each beneficiary provided that the
beneficiary's interest in the account is non-
contingent (i.e., capable of determination
without evaluation of contingencies). The
deposit insurance of each beneficiary's
interest is separate from the coverage
provided for other accounts maintained by
the beneficiary, the grantor, the trustee, or
other beneficiaries. A beneficiary’s interest in
funds held in irrevocable trust accounts
created by the same person will be
aggregated and insured up to $250,000 at
each Program Bank.

Individual Retirement Accounts - Deposits

held in Individual Retirement Accounts,
including Traditional, Roth, SEP, and
SIMPLE IRAs, are eligible for FDIC insurance
of up to $250,000 in the aggregate at a bank
(currently providing a total of up to
$1,250,000 when deposited at all five of the
Program Banks).

578326 (Rev 43 - 09/22) Page 8 of 8

Traditional Individual Retirement Account
Disclosure Statement and
Custodial Agreement

Effective January 15, 2022

Investment and Insurance Products are:

• Not Insured by the FDIC or Any Federal Government Agency
• Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate
• Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested
Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC (WFCS), Member SIPC, a registered broker-dealer and non-bank
affiliate of Wells Fargo & Company. WellsTrade brokerage accounts are offered through WFCS.

544408 (Rev 28 - 01/22) Page 1 of 21

Table of Contents

Section I: Disclosure Statement

A. Introduction 3
B. Contributions to Your Traditional IRA 3
C. Rollover Contributions 5
D. Withdrawals from Your Traditional IRA 6
E. Conversion of a Traditional IRA to a Roth IRA 7
F. Re-characterization of IRA Contributions 7
G. Excess Contributions and Prohibited Transactions 7
H. Investments 8
I. Other Questions and Answers 8

Section II: WFCS Traditional IRA Custodial Agreement

Article I 10
Article II 10
Article III 10
Article IV 10
Article V 11
Article VI 11
Article VII 12
Article VIII 12
1. Definitions 12
2. Resignation of Custodian/Designation of New Custodian 12
3. Distributions 12
4. Beneficiary 13
5. Investments 14
6. Taxes 15
7. Excess Contributions 15
8. Amendment 15
9. Termination 15
10. General Provisions 16
11. Sharing Information 17
12. Limitations on Custodial Liability and Indemnification 17
13. Recording Conversations 18
14. Holding Account Assets 18
15. Counterparts 18

Section III: Additional Information

A. Periodic Statements For Your IRA Investment Options 18
B. How to Determine Your Annual Contributions to Date 18
C. Tax Reporting 18

Appendix
IRS Approval Notification Letter 19

544408 (Rev 28 - 01/22) Page 2 of 21

WFCS Traditional Individual Retirement Account
Disclosure Statement & Custodial Agreement
Effective January 15, 2022

Section I: Disclosure Statement

A. Introduction
Wells Fargo Clearing Services, LLC (WFCS) is the custodian of your Traditional Individual Retirement Account.
WFCS and its affiliates are also referred to in this Disclosure Statement as “we,” “us” or “our”. The custodian of a
Traditional Individual Retirement Account must be a bank or an entity meeting standards established by the
Secretary of the Treasury. We have been approved by the Internal Revenue Service (“IRS”) to act as the custodian of
your Traditional Individual Retirement Account (“Traditional IRA”). Please note that Wells Fargo Clearing Services,
LLC was originally known as Wachovia Securities, LLC. In 2009, Wachovia Securities, LLC was renamed Wells
Fargo Advisors, LLC. In 2016, Wells Fargo Advisors, LLC was renamed Wells Fargo Clearing Services, LLC due to a
subsequent merger. Please read this Disclosure Statement and the attached materials carefully. Please note that the
rules regarding Traditional IRAs are subject to frequent change. Before entering into any major transaction involving
your Traditional IRA, you should make sure that you have the most current information available. If you have any
legal or tax questions concerning your Traditional IRA, we urge you to discuss them with your attorney or personal
tax consultant. We will, of course, be happy to answer any questions concerning the operation and financial aspect of
your Traditional IRA, but cannot give you legal or tax advice. You may obtain further information on Traditional IRAs
from your District Office of the IRS. In particular, you may wish to obtain IRS Publication 590A and 590B (Publication
590) Individual Retirement Arrangements (IRAs) at www.irs.gov.
A1. How do I open a Traditional IRA?
Complete an IRA enrollment/application form and return it to us. Submit your initial contribution.
A2. May I cancel my Traditional IRA?
Yes, but to receive a full refund without penalty on your initial contribution, you must do so on or before the seventh
(7th) day after you receive the Traditional IRA Custodial Agreement ("Custodial Agreement") and Disclosure
Statement. To cancel your Traditional IRA, either deliver a written notice of cancellation or mail one to the address
shown below before the end of the 7-day period (deemed mailed by postmark date). If the Custodial Agreement is
mailed to you, you will be deemed to have received it 7 days after the postmark absent evidence to the contrary. If an
important change is made to the Disclosure Statement or your Traditional IRA during the 7-day period, we will notify
you of the change and you will have an additional 7 days from the date you receive the notice to revoke your
Traditional IRA.

Wells Fargo Clearing Services, LLC

Attn: IRA Department MAC H0006-083
One North Jefferson Ave.
St. Louis, MO 63103

Until the 7-day period for revoking your Traditional IRA has lapsed, contributions may be accepted, but investment
instructions may be restricted.

If you revoke your Traditional IRA within the 7-day period, we will return to you the entire amount of the contributions
contributed before your revocation. You will not earn interest on the contribution if you revoke. There will be no
adjustments for administrative expenses, or changes in the market value. When you revoke your Traditional IRA, the
initial contribution and return of the contribution are reported to the IRS. You should consult your tax advisor if you
have any questions about taxes.

A3. Is my Traditional IRA non-forfeitable?

Your interest in your Traditional IRA is non-forfeitable at all times.

A4. Is my Traditional IRA approved by the Internal Revenue Service?

Since the Custodial Agreement establishing your Traditional IRA utilizes IRS Form 5305-A, as currently provided by
the IRS, your Traditional IRA will be treated as approved as to form. IRS approval is a determination as to the form of
your Traditional IRA but does not represent a determination of its merits.
In the event that the laws governing Traditional IRAs are amended or changed and cause differences between our
current Custodial Agreement and the new laws, we will administer your Traditional IRA in accordance with the new
laws and amend the Custodial Agreement when revised IRS forms are published.

B. Contributions to your Traditional IRA

B1. What is a Traditional IRA contribution?
There are three types of Traditional IRA contributions:
An "annual contribution" is a cash deposit to your Traditional IRA that may be deductible on your federal income tax
return up to the amount fixed by federal law. Individuals who are age 50 and older can contribute an additional
"catch-up" amount beginning in the taxable year in which the individual turns age 50.
544408 (Rev 28 - 01/22) Page 3 of 21
A "rollover contribution" is a deposit to your Traditional IRA of funds that you receive from either an employer
retirement plan or another eligible IRA. A rollover contribution is not deductible and is subject to special rules as
discussed in Section D: Rollover Contributions.
An "employer contribution" if your employer maintains a Simplified Employee Pension (SEP).
B2. May I contribute to a Traditional IRA?
You may establish and/or contribute to a Traditional IRA if, at the end of a tax year you (or your spouse if filing jointly)
have received compensation from employment for that year. Generally, compensation includes salary, wages,
commissions, fees, tips and other income you (or your spouse if filing jointly) receive for your personal services. It
does not include items such as earnings and dividends on investments, deferred compensation or monies from
retirement plans or annuities.
You are allowed to direct that all or a portion of your federal income tax refund be paid directly to your Traditional
IRA, or your spouse’s Traditional IRA if you file jointly.
B3. How much may I contribute?
The total annual contributions allowed to all of your Traditional and Roth IRAs is the lesser of the compensation you
and your spouse receive for that year (less any Traditional and Roth IRA contributions made by or on behalf of your
spouse) or the maximum amount as determined by federal tax laws. Refer to the IRS Publication 590 or www.irs.gov
for current contribution limits. Unless otherwise specified, for purposes of explaining how much you may contribute to
a Traditional IRA, this disclosure statement assumes that you will not make contributions to a Roth IRA.
If you contribute more than you are allowed for a tax year, you may incur an excise tax for an "excess contribution."
B4. Active Participant.
You are an "Active Participant" for a year if you are covered by a retirement plan. You are covered by a "retirement
plan" for a year if your employer or union has a retirement plan under which money is added to your account. Your
Form W-2 for the year should indicate your participant status.
B5. How much of my annual contribution is tax-deductible for federal income tax purposes?
If neither you, nor your spouse is an Active Participant, you may make and deduct the maximum contribution to your
IRA and the maximum contribution to your spouse’s IRA, as long as the total contributions to both IRAs do not
exceed 100% of your compensation for the year.
If you are an Active Participant but have a modified adjusted gross income (MAGI) below a certain level, you may
make a deductible contribution. If, however, you or your spouse are an active participant and your MAGI is above the
specified level, the amount of the deductible contribution you may make to a Traditional IRA is phased down and
eventually eliminated.
The determination of active participation is made separately for you and your spouse. However, if you are not an
active participant, but your spouse is an active participant, your maximum deduction for IRA contributions may be
limited depending on your MAGI.
(a) Deductibility Limits.
Single and joint filers who are Active Participants may receive a full or partial deduction for their contributions based
on their income thresholds. Contact us, refer to IRS Publication 590-A or visit www.irs.gov for more information on
deductibility limits. Except for married individuals filing separately, the MAGI limits will be indexed to reflect inflation in
the future.
If you are married but file a separate tax return and your spouse is an Active Participant you may make deductible
contributions if you and your spouse lived apart at all times during the year.
(b) Tax Credit.
You may be eligible for a nonrefundable tax credit of "qualified retirement savings contributions," provided your
adjusted gross income is within specified limits. "Qualified retirement savings contributions" include contributions to a
Traditional IRA, Roth IRA, elective deferrals to a qualified retirement plan, elective deferrals under an eligible
deferred compensation plan maintained by a state or local government, and voluntary employee contributions to a
qualified retirement plan. You can obtain additional information on this tax credit in IRS Publication 590 or go to the
IRS website at www.irs.gov.
B6. May I make a nondeductible contribution?
Even if you are above the threshold level to make a deductible contribution, you may still contribute, subject to the
applicable contribution limits. If you make a nondeductible contribution to a Traditional IRA you must report the
amount to the IRS by filing Form 8606 Nondeductible IRAs with your tax return for the year for which the contribution
is made.
B7. May my employer contribute to my Traditional IRA for me?
If your employer has a SEP or a SIMPLE IRA retirement plan and you are a participant, the amount your employer
contributes for you under the SEP or SIMPLE IRA retirement plan does not reduce the amount you may contribute to
your Traditional IRA but may reduce the deductible amount of your contribution by making you an "Active
Participant."

544408 (Rev 28 - 01/22) Page 4 of 21

Your employer may make payments to your SEP-IRA. In addition to your employer’s contributions, you may make an
annual contribution to your own Traditional IRA as described above. SEP-IRA and SIMPLE IRA contributions made
by your employer are excluded from your income rather than deducted by you on your tax return.
B8. When may I contribute to my Traditional IRA?
Traditional IRA contributions for a calendar year taxpayer may be made at any time during the calendar year or no
later than April 15th of the following year (or that calendar year's tax filing deadline). This applies even if you receive
an extension for filing your return. If you make a contribution after the end of the calendar year (but no later than the
calendar year's tax filing deadline) that is intended to be a contribution for the prior year, you must inform us in writing
at the time of your deposit.

C. Rollover Contributions
C1. What is a rollover contribution?
A rollover contribution is a deposit to a Traditional IRA of funds you receive as an eligible rollover distribution from
either an Employer Retirement Plan, another Traditional IRA (including a SEP-IRA), or a SIMPLE IRA. A rollover
contribution allows you to continue deferring income tax on the amount you roll over and its subsequent earnings.
You may also roll over distributions from an eligible state or local government deferred compensation plan (section
457 plan) into a Traditional IRA. A rollover is often complex and we suggest you seek professional tax advice before
receiving and rolling over a distribution.
Employer Retirement Plans are pension, profit sharing, thrift, employee stock ownership, stock bonus, SIMPLE IRA
retirement or self-employed retirement plans. They also include annuity plans for employees of certain tax-exempt
employers and certain governmental retirement plans.
C2. What Employer Retirement Plan distributions may be rolled over into a Traditional IRA?
Most distributions received from Employer Retirement Plans except certain periodic distributions, excess
contributions, required minimum distributions (RMDs) after reaching age 72, hardship distributions, and dividend
distributions from certain ESOPs, may be rolled over to Traditional IRAs.
We suggest that you seek professional tax advice before you request and receive your distribution.
C3. May I roll over distributions from another IRA?
You may roll over to your Traditional IRA one distribution you took from another Traditional IRA (including a SEP-
IRA) as long as you have not made such a rollover of any of your IRAs in the previous 12 months (or consecutive 365
days). You may roll over to your Traditional IRA amounts that are distributed from a SIMPLE IRA if you participated in
the SIMPLE IRA for at least two years. Additionally, you may roll over amounts from your Traditional IRA to a
SIMPLE IRA if you have participated in the SIMPLE IRA for at least two years. You may not roll over to your
Traditional IRA amounts distributed from a Roth IRA or Coverdell Education Savings Account. For additional
resources and information regarding IRA rollovers, visit www.irs.gov.
C4. Is there a deadline for making a rollover contribution?
Yes, you must complete a rollover contribution within 60 days after you receive an eligible rollover distribution from an
Employer Retirement Plan or a distribution from another eligible IRA. If you do not complete the rollover within the 60-
day period, the amount of the distribution will be taxable as ordinary income for the year in which it was received and
may be subject to an IRS 10% additional tax. The IRS may, in some very limited instances such as in case of a
disaster, casualty or other events beyond your reasonable control, waive the 60-day limitation. You should contact
your tax advisor if you believe that you may qualify for a waiver.
C5. May I make a rollover from my Traditional IRA into an Employer Retirement Plan?
Generally, you may make a rollover from your Traditional IRA into an Employer Retirement Plan, if the plan permits.
You should seek professional tax advice if you plan on making a rollover contribution to an Employer Retirement Plan
as these rules differ from rolling from a plan to an IRA.
C6. May a beneficiary’s distribution be rolled over or transferred?
If you are a spouse beneficiary and receive a partial or total distribution that could have been rolled over by your
spouse before death into a Traditional IRA, you may roll the distribution over in the same manner as your deceased
spouse. A spouse may also be able to roll this distribution into another Employer Retirement Plan subject to
limitations imposed by the receiving plan.
A direct transfer from a deceased participant's Employer Retirement Plan (including plans maintained under Code
sections 401(a), 403(a), 403(b) and plans maintained under Code section 457(b) by a state or local government) to a
Traditional IRA established on your behalf can be treated as an eligible rollover distribution if you are the designated
beneficiary of the deceased participant's plan benefit. You do not have to be the deceased participant's spouse for
this special rule to apply. The Traditional IRA is treated as an inherited Traditional IRA and is subject to the
distribution rules. As an inherited IRA, the inherited Traditional IRA may not accept contributions or later be rolled
over to another IRA or retirement plan.
C7. May I transfer funds directly from one Traditional IRA to another?
Yes. Instead of making a rollover contribution, you may transfer funds held in a previously established Traditional IRA
to a new Traditional IRA by giving directions for the transfer to the Trustee/Custodian of each Traditional IRA.
Transfers are not subject to the “once every 365 days rule” of rollover contributions.
544408 (Rev 28 - 01/22) Page 5 of 21
C8. May I transfer funds directly from my Traditional IRA to my HSA?
If you are otherwise eligible to make contributions to a health savings account ("HSA"), you may elect to make a once
in a lifetime transfer from your Traditional IRA to your HSA on a tax-free basis. The transfer election is irrevocable.
This special transfer only applies to amounts in your Traditional IRA that would otherwise be taxable if distributed.
Special rules apply to determine the amount that may be transferred. Transfers from SEP-IRAs and SIMPLE IRAs to
HSAs are not permitted.
C9. May I repay a distribution I've taken due to special tax relief provisions?
You may be able to repay the distribution to your Traditional IRA. Please consult your tax advisor for more
information if you think that you may be eligible for a special repayment opportunity.

D. Withdrawals from your Traditional IRA

D1. When may I make a withdrawal from my Traditional IRA?
You may withdraw funds from your Traditional IRA at any time before or after you retire. If, however, you make
withdrawals before age 59½, you may be subject to an IRS 10% additional tax on the amounts withdrawn.
D2. What is the early distribution additional tax?
If you make a withdrawal before age 59½ and do not roll over the amount taken, you will have to pay a 10%
additional tax on the amount included in gross income, unless you qualify for one of the exceptions to the 10%
additional tax. Examples of these exceptions include distributions on account of or for: your permanent disability; your
death; certain medical expenses; health insurance premiums while you are unemployed; qualified higher education
expenses; certain costs of acquiring a principal residence; a federal tax levy on your Traditional IRA; a "qualified
reservist distribution;" birth or adoption expenses; or payments as a series of substantially equal periodic payments.
The additional tax for early distribution is on top of the income taxes which are payable on the taxable amount
withdrawn. Please consult your tax advisor and/or review IRS Publication 590-B to determine if these exceptions
apply to your particular situation.
D3. How about income tax withholding?
Federal tax laws require us to generally withhold 10% of each withdrawal by you for payment of your federal income
taxes, unless you instruct us in writing not to withhold. Additionally, certain states require us to withhold from your
distribution. Please consult your state tax authority to determine if your state requires withholding.
D4. When must I start making withdrawals?
You may incur an excise tax if you do not start making withdrawals by April 1st following the year you become age
72. Before that date, you must either withdraw the balance from your account or begin making periodic withdrawals
that are at least as great as the minimum amount you are required to withdraw for that year under federal laws. You
may elect to receive the minimum amount that applies to this Traditional IRA from another Traditional IRA. If you
make this election you should notify us. The excise tax is 50% of the difference between the minimum amount you
are required to withdraw and the amount you actually withdrew in that year. NOTE: If you turned age 70½ prior to
December 31, 2019, you were required to begin distribution the year you turned age 70½. The age for required
distributions changed effective after December 31, 2019.
D5. What is the minimum amount I must withdraw after age 72?
Generally, after age 72, the minimum amount you must withdraw each year to avoid the 50% excise tax is based on
the account balance of your Traditional IRA on December 31 from the prior year divided by a factor determined by
your age published by the IRS on the uniform life expectancy table. If you name your spouse as the sole primary
beneficiary of your Traditional IRA for the entire year and your spouse is more than years younger than you, the
appropriate factor is found in the IRS’s Joint Life and Last Survivor Expectancy table, which will further reduce the
amount of your required distribution.
IRS Publication 590 explains the rules for determining the minimum amounts you must withdraw.
It is your responsibility to notify us of the dollar amount that you wish to receive as a required minimum distribution
and when you wish to receive it. If the balance in your Traditional IRA at the time set for distribution is less than the
distribution amount you have specified, we may only distribute that balance or ask that you take additional action.
Except as provided below, we are not responsible for determining the required minimum distribution amount. We will
provide you with a notice by January 31 of each year that either (a) indicates the required minimum distribution and
deadline for distribution or (b) notifies you that a required minimum distribution is due and the deadline for such
distribution and offer to calculate the required minimum distribution upon your written request. Also, if a required
minimum distribution is due, you will be advised by January 31 of that year in the December 31 IRA fair market value
statement. The IRS will be advised on Form 5498 if a required distribution is due from your Traditional IRA. These
reporting requirements only apply to you (or to your eligible spouse who elects to treat the Traditional IRA as his or
her own). We may, but are not required to provide such reports to your beneficiary.
D6. What happens to my Traditional IRA when I die?
Your account balance will be paid to your beneficiary. Your beneficiary is the person or persons you designate when
you open your Traditional IRA. You may change your beneficiary designation at any time by contacting us and
following the appropriate procedure. Each valid beneficiary designation you file with us will cancel all previous
designations. A beneficiary is subject to and bound by all the terms and conditions of the Traditional IRA Custodial
544408 (Rev 28 - 01/22) Page 6 of 21
Agreement and Disclosure Statement. A beneficiary is required to complete and submit any and all forms deemed
necessary by the Custodian in order to process a transaction such as a distribution or transfer.
If a designated beneficiary (including any contingent beneficiary) does not survive you, such beneficiary’s interest
shall lapse, and the percentage interest of any remaining beneficiary (including any contingent beneficiary) shall be
increased on a pro rata basis unless your beneficiary designation allows otherwise.
If a designated beneficiary (including any contingent beneficiary) does not survive you or if there is no record of a
valid designated beneficiary, your Traditional IRA balance will be paid to your spouse. If you are not survived by a
spouse, your account will be paid to your surviving children as determined under state law. In such case, a legal or
personal representative is required to provide us with a written certification listing the names of your surviving
children as determined under state law. If there is no legal or personal representative, then a court order may be
required. If you are not survived by a spouse or by any of your children, as certified by your legal or personal
representative or by a court order, then your Traditional IRA will be paid to your estate.
If you are divorced at the time of your death and your former spouse is named as beneficiary of your Traditional IRA,
your former spouse will be treated as having predeceased you, unless you designated him or her as your beneficiary
AFTER the date of the divorce or unless a court order provides otherwise.

E. Conversion of a Traditional IRA to a Roth IRA.

E1. May I convert all or part of my Traditional IRA to a Roth IRA?
Yes. Any Traditional IRA amount converted to a Roth IRA must also satisfy the IRA rollover requirements.
Because of the strict rules that apply to conversions and distributions taken from Roth IRAs within five years after a
conversion, you should seek professional tax advice before converting your Traditional IRA to a Roth IRA.
E2. Will I be taxed on the conversion?
Yes. The amount converted from your Traditional IRA will be included in your gross income (except for the portion of
the converted amount, if any, which represents a tax-free return of your nondeductible contributions or after-tax
amounts you rolled over to your Traditional IRA from an employer retirement plan). The amount converted will not be
subject to the 10% additional tax on early distributions, regardless of whether you are under age 59½.

E3. When will I be taxed on the conversion?

Generally, conversions will be taxed in the year of distribution from the Traditional IRA.

F. Recharacterization of IRA Contributions

F1. May I recharacterize contributions made to my Traditional or Roth IRA for a tax year as contributions
made to a different type of IRA?
Yes. You may recharacterize your Traditional IRA contributions for a tax year by transferring (in a trustee-to-trustee
transfer) the Traditional IRA contributions (or a portion of the contributions) and the related earnings to a Roth IRA,
and vice versa. The recharacterization must be completed before the due date for filing your federal income tax
return (including extensions) for the tax year for which the contribution was made. The contribution will be treated as
having been made to the second IRA on the same date and for the same taxable year as the contribution was
originally made to the first IRA for federal tax purposes. Once a recharacterization is made it may not be revoked.
F2. Is a recharacterization treated as a rollover for purposes of the one-rollover-per-year limitation?
No. Recharacterizing a contribution is not treated as a rollover for purposes of the one-rollover-per-year limit.

G. Excess Contributions and Prohibited Transactions

G1. What is an excess contribution?
An excess contribution is any amount you contribute to your Traditional IRA for a tax year that exceeds the maximum
amount you are permitted to contribute for that tax year. There is a 6% excise tax on an excess contribution for each
year that it remains in your Traditional IRA.
G2. How may I avoid the 6% excise tax?
If you withdraw the excess contribution for a year and any earnings or losses on it before the filing date of your
income tax return for that year, including extensions (or any other time permitted by the IRS), you will not have to pay
the 6% excise tax. If you do not withdraw the excess contribution by that date, you will be charged the 6% excise tax
for that year. In order to avoid subsequent excise taxes, you must either:
a. contribute less than the maximum allowable contribution in later years, or
b. withdraw the excess contribution in accordance with applicable rules.
G3. What is a prohibited transaction?
Generally, a prohibited transaction is any improper use of your Traditional IRA by you, your beneficiary or any
disqualified person. Prohibited transactions include such actions as you selling property to your Traditional IRA or
buying property from it. To learn more about prohibited transactions and who are disqualified persons, refer to IRS
Publication 590.
544408 (Rev 28 - 01/22) Page 7 of 21
G4. What happens if I engage in a prohibited transaction?
If you or your beneficiary engages in a prohibited transaction, your Traditional IRA will lose its tax-exempt status and
you will have to include the entire balance (subject to any applicable basis therein) in your taxable income for that
year. Furthermore, you will be subject to the 10% additional tax on the entire balance unless you are over age 59½ or
meet one of the other exceptions to the additional tax. If someone other than you or your beneficiary engages in a
prohibited transaction with respect to your Traditional IRA, that person may be liable for certain excise taxes.

H. Investments
H1. Who is responsible for investing my Traditional IRA assets?
You are solely responsible for making any investment decision regarding your Traditional IRA assets. You may
designate someone other than yourself to direct the investment of the assets in your Traditional IRA by executing a
valid third party trading authorization or power of attorney in a form acceptable to us and by naming a person or entity
acceptable to us. All investment directions shall be given in a form that complies with the reasonable requirements
and procedures imposed by us. Such requirement may include that certain representations and warranties
accompany certain directions, including indemnification. The Custodian has no investment advice duties and shall
only make investments pursuant to your (or your duly authorized representative's) direction and will not question such
direction. In addition, the Custodian its employees and affiliates are indemnified and held harmless for any liability
which may arise in our performance of our duties under the Custodial Agreement, except for any liability arising from
gross negligence or willful misconduct.
H2. What assets may not be held in my Traditional IRA?
The Custodian in its sole discretion, may refuse to hold any investment. Your Traditional IRA may not be invested in
life insurance contracts and, except for investments pooled in a common trust fund or common investment fund, may
not be commingled with other property. Further, assets in your Traditional IRA may not be invested in commodities,
"collectibles," alcoholic beverages, or any other tangible personal property. The term "collectibles" includes works of
art, rugs, antiques, metals, gems, stamps, coins (other than certain gold, silver or platinum coins of the United States
or a state and certain bullion, if on the Custodian’s approved list of investments). You also may not invest the assets
of your Traditional IRA in any investments we determine, in our sole discretion, are administratively or operationally
burdensome.
The Custodian has no responsibility for monitoring your Traditional IRA investments. Thus, if you or your duly
authorized representative direct us to engage in any a non-qualifying or prohibited transaction or investment with
respect to your Traditional IRA, neither the Custodian, its affiliates nor any of our employees will be liable for any
adverse investment, tax or other legal consequences that may result from such purchase. Also, if your investment
direction results in a prohibited transaction, the tax-favored status of your Traditional IRA will be affected.
H3. Is any interest earned on amounts awaiting investment or disbursement?
The Custodian or an affiliate may retain any interest earned on assets awaiting investment or disbursement. You
understand and agree that this interest (generally referred to as "float") will be retained by us as additional
compensation for the provision of services with respect to your Traditional IRA. Such interest shall generally be a
prevailing interest rate.
Assets awaiting investment include (a) new deposits to the Traditional IRA, including interest and dividends, and (b)
any uninvested assets held by the Traditional IRA caused by an instruction to us to purchase or sell securities where
investment instructions are received too late in the day to be completed. We may also earn float on distributions from
the time funds are distributed from your IRA until you cash the check or other payment method is completed.

I. Other Questions and Answers

I1. Am I required to file any tax forms for my Traditional IRA?
Generally, you will not be required to file any special forms for your Traditional IRA. However, you must file a Form
5329 Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts, with the IRS for any
year for which: (1) you are subject to the 6% excise tax for excess contributions; (2) you are subject to the 10%
additional tax for distributions for withdrawals before age 59½ and the proper distribution code is not shown on your
Form 1099-R Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts,
etc.; (3) you meet an exception to the 10% additional tax, but the proper distribution code is not shown on your Form
1099-R; or (4) you or your beneficiary are subject to the 50% excise tax for failing to take a minimum distribution after
you reach age 70½. Also, you must file a Form 8606 Nondeductible IRAs for any year in which you make a
nondeductible contribution to your Traditional IRA, you received distributions from your Traditional IRA and your basis
is more than zero or you convert all or any portion of your Traditional IRA into a Roth IRA.
I2. Does the custodian report any information about my Traditional IRA to the Internal Revenue Service?
All IRA custodians are required to report various IRA transactions to the IRS, Social Security Administration and the
State Revenue Department.
Form 5498 reports annual, rollover and recharacterized contributions, plus the December 31 fair market value of your
account. Form 5498 also reports if a required minimum distribution is required to be made to you for the following
year.
Partial withdrawals, periodic distributions, and total distributions are reported on Form 1099-R. Unrelated business
taxable income is reported on Form 990-T.

544408 (Rev 28 - 01/22) Page 8 of 21

I3. Can my Traditional IRA be changed?
Yes. We may amend your Traditional IRA Custodial Agreement by mailing you a copy of the change. You will be
deemed to have automatically consented to any amendment, unless we receive written notice to the contrary within
30 days after a copy of the amendment is first mailed to you. Any notice we send you will be mailed or delivered to
the last address that we have for you in our records. Although other amendments may be made, generally
amendments will be made only to comply with changes in tax law. No amendment can take any part of your IRA
away from you or your beneficiary.
I4. Will my Traditional IRA be charged any fees?
Yes, all of the fees that may apply to your account are outlined in the fee schedule/notice you will receive when your
account is opened. The fee schedule/notice may be changed from time to time, upon 30 days written notice to you. In
addition, all of the fees that apply to brokerage accounts will also apply to your account including fees associated with
the automatic cash investment service. Please review your relevant account opening documents for descriptions of
these fees. If you do not pay fees by the due date, we may deduct these fees from your Traditional IRA.
I5. How do Traditional IRAs compare to Roth IRAs?
Below is a comparison chart that you should review to help you determine which type of IRA would best suit your
needs:

What is/are my Traditional IRA Roth IRA

Tax Benefits • Tax-deferred earnings • Tax-advantaged earnings
• Contributions may be tax-deductible subject • Tax-free qualified distributions*
to Modified Adjusted Gross Income (MAGI)
limits
Deductibility Deductibility is determined by your Contributions are not deductible.
compensation & modified adjusted gross
income level, your federal filing status and
your coverage under a workplace retirement
plan. Refer to the IRS Publication 590 or
www.irs.gov for specifics regarding
deductibility limits for each tax year.
Required Minimum RMDs are required beginning at age 72. None during your lifetime
Distribution
Taxes on • Before-tax contributions and any earnings • Contributions are always withdrawn tax-
Distributions are subject to ordinary income tax. free.
• If you have before- and after-tax amounts in • Qualified distributions are tax-free.
any of your Traditional, SEP, or SIMPLE Distributions are qualified after five years and
IRAs, all distributions or conversions are age 59½ or you are disabled, or using the
taken on pro rata basis. first time homebuyer exception, or taken by
• You may be subject to a 10% additional tax your beneficiaries due to your death.
unless an exception applies. • A non-qualified distribution may be subject
to ordinary income tax and an IRS 10%
additional tax unless an exception applies.
Eligibility Must have earned income to contribute to an IRA
Contribution Limits Federal tax laws determine how much you may contribute. In any year you or your spouse
receive compensation, you may make total annual contributions to all of your Traditional and
Roth IRAs in any amount up to the lesser of the compensation you and your spouse receive
for that year (less any Traditional and Roth IRA contributions made by or on behalf of your
spouse) or the maximum amount as determined by federal tax laws. Refer to the IRS
Publication 590 or www.irs.gov for current contribution limits. Contributions must be made in
cash, check, or money order. Contributions cannot be made in-kind, i.e., securities, property.
Exception to 10% Exceptions to the 10% additional tax are for distributions after reaching age 59½, death,
Additional Tax disability, eligible medical expenses, certain unemployed individuals' health insurance
premiums, qualified first-time homebuyer ($10,000 lifetime maximum), qualified higher
education expenses, Substantially Equal Periodic Payments (SEPP), Roth conversions,
qualified reservist distribution, birth or adoption expenses (up to $5,000), or IRS levy.

544408 (Rev 28 - 01/22) Page 9 of 21

Section II: WFCS Traditional IRA Custodial Agreement
Wells Fargo Clearing Services, LLC, a firm with its principal office in St. Louis, Missouri and a non-bank IRA
custodian ("Custodian") hereby establishes the "Wells Fargo Clearing Services, LLC Traditional Individual Retirement
Custodial Account" ("Custodial Account" or "IRA") as a custodial account for an eligible customer ("Depositor") who
enters into the Traditional IRA Account Custodial Agreement ("Agreement") as set forth herein by executing an IRA
enrollment/application form.
WFCS TRADITIONAL INDIVIDUAL RETIREMENT CUSTODIAL ACCOUNT
(Under section 408(a) of the Internal Revenue Code)
Form 5305-A (April 2017)
Department of the Treasury, Internal Revenue Service
The Depositor whose name appears on the Depositor’s IRA enrollment/application form is establishing a Traditional
Individual Retirement Account under section 408(a) to provide for his or her retirement and for the support of his or
her beneficiaries after death.
The Custodian has given the Depositor the disclosure statement required by Regulations section 1.408-6.
The Depositor has assigned the Custodial Account the sum shown on the Depositor’s Contribution Form.
The Depositor and the Custodian make the following agreement:

Article I
Except in the case of a rollover contribution described in section 402(c), 403(a)(4), 403(b)(8), 408(d)(3), or 457(3)
(16), an employer contribution to a simplified employee pension plan as described in section 408(k), or a
recharacterized contribution described in section 408A(d)(6), the Custodian will accept only cash contributions up to
$5,500 per year for tax years 2013 through 2017. For individuals who have reached the age of 50 before the close of
the tax year, the contribution limit is increased to $6,500 per year for tax years 2013 through 2017. For tax years after
2017, the above limits may be increased to reflect a cost-of-living adjustment, if any.

Article II
The Depositor’s interest in the balance in the Custodial Account is non-forfeitable.

Article III
1. No part of the Custodial Account funds may be invested in life insurance contracts, nor may the assets of the
Custodial Account be commingled with other property except in a common trust fund or common investment
fund (within the meaning of section 408(a)(5)).
2. No part of the Custodial Account funds may be invested in collectibles (within the meaning of section 408(m)
except as otherwise permitted by section 408(m)(3), which provides an exception for certain gold, silver, and
platinum coins issued under the laws of any state, and certain bullion.

Article IV
1. Notwithstanding any provision of this Agreement to the contrary, the distribution of the Depositor’s interest in
the Custodial Account shall be made in accordance with the following requirements and shall otherwise
comply with section 408(a)(6) and the regulations thereunder, the provisions of which are incorporated herein
by reference.
2. The Depositor’s entire interest in the Custodial Account must be, or begin to be, distributed not later than the
Depositor’s required beginning date, April 1 following the calendar year in which the Depositor reaches age
70½. By that date, the Depositor may elect, in a manner acceptable to the Custodian, to have the balance in
the Custodial Account distributed in:
a. A single sum or
b. Payments over a period not longer than the life of the Depositor or the joint lives of the Depositor and his
or her designated beneficiary.
3. If the Depositor dies before his or her entire interest is distributed to him or her, the remaining interest will be
distributed as follows:

a. If the Depositor dies on or after the required beginning date and:

i. the designated beneficiary is the Depositor’s surviving spouse, the remaining interest will be distributed
over the surviving spouse’s life expectancy as determined each year until such spouse’s death, or over
the period in paragraph (a)(iii) below if longer. Any interest remaining after the spouse’s death will
be distributed over such spouse’s remaining life expectancy as determined in the year of the
spouse’s death and reduced by 1 for each subsequent year, or, if distributions are being made over the
period in paragraph (a)(iii) below, over such period.

544408 (Rev 28 - 01/22) Page 10 of 21

 ii. the designated beneficiary is not the Depositor’s surviving spouse, the remaining interest will
be distributed over the beneficiary’s remaining life expectancy as determined in the year following
the death of the Depositor and reduced by 1 for each subsequent year, or over the period in
paragraph (a)(iii) below if longer.

iii. there is no designated beneficiary, the remaining interest will be distributed over the remaining
life expectancy of the Depositor as determined in the year of the Depositor’s death and reduced by 1
for each subsequent year.

b. If the Depositor dies before the required beginning date, the remaining interest will be distributed in
accordance with (i) below or, if elected or there is no designated beneficiary, in accordance with (ii)
below:

i. The remaining interest will be distributed in accordance with paragraphs (a)(i) and (a)(ii) above (but
not over the period in (a)(iii), even if longer), starting by the end of the calendar year following the
year of the Depositor’s death. If, however, the designated beneficiary is the Depositor’s surviving
spouse, then this distribution is not required to begin before the end of the calendar year in which the
Depositor would have reached age 70½. But, in such case, if the Depositor’s surviving spouse dies
before distributions are required to begin, then the remaining interest will be distributed in
accordance with (a)(ii) above (but not over the period in paragraph (a)(iii), even if longer), over such
spouse’s designated beneficiary’s life expectancy, or in accordance with (ii) below if there is no such
designated beneficiary.

ii. The remaining interest will be distributed by the end of the calendar year containing the
fifth anniversary of the Depositor’s death.

4. If the Depositor dies before his or her entire interest has been distributed and if the designated beneficiary is
not the Depositor’s surviving spouse, no additional contributions may be accepted in the account.

5. The minimum amount that must be distributed each year, beginning with the year containing the Depositor’s
required beginning date, is known as the "required minimum distribution" and is determined as follows:

a. The required minimum distribution under paragraph 2(b) for any year, beginning with the year the
Depositor reaches age 70½, is the Depositor’s account value at the close of business on December 31 of
the preceding year divided by the distribution period in the uniform lifetime table in Regulations section
1.401(a)(9)-9. However, if the Depositor’s designated beneficiary is his or her surviving spouse, the
required minimum distribution for a year shall not be more than the Depositor’s account value at the close
of business on December 31 of the preceding year divided by the number in the joint and last survivor
table in Regulations section 1.401(a)(9)-9. The required minimum distribution for a year under this
paragraph (a) is determined using the Depositor’s (or, if applicable, the Depositor and spouse’s) attained
age (or ages) in the year.

b. The required minimum distribution under paragraphs 3(a) and 3(b)(i) for a year, beginning with the year
following the year of the Depositor’s death (or the year the Depositor would have reached age 70½, if
applicable under paragraph 3(b)(i)) is the account value at the close of business on December 31 of the
preceding year divided by the life expectancy (in the single life table in Regulations section 1.401(a)(9)-9)
of the individual specified in such paragraphs 3(a) and 3(b)(i).

c. The required minimum distribution for the year the Depositor reaches age 70½ can be made as late as
April 1 of the following year. The required minimum distribution for any other year must be made by the
end of such year.

6. The owner of two or more Traditional IRAs may satisfy the minimum distribution requirements described
above by taking from one Traditional IRA the amount required to satisfy the requirement for another in
accordance with the regulations under section 408(a)(6).

Article V
1. The Depositor agrees to provide the Custodian with all information necessary to prepare any reports required
under section 408(i) and Regulations sections 1.408-5 and 1.408-6.

2. The Custodian agrees to submit to the Internal Revenue Service (“IRS”) and the Depositor the reports
prescribed by the IRS.

Article VI
Notwithstanding any other articles which may be added or incorporated, the provisions of Articles I through III and
this sentence will be controlling. Any additional articles that are not consistent with section 408(a) and the related
regulations will be invalid.

544408 (Rev 28 - 01/22) Page 11 of 21

Article VII
This Agreement will be amended from time to time to comply with the provisions of the Code and the related
regulations. Other amendments may be made with the consent of the persons whose signatures appear on the IRA
enrollment/application form.

Article VIII
1. Definitions.

a. "Beneficiary" means the person or persons designated in accordance with paragraph 4.

b. "Broker" means the Introducing Firm and any other broker-dealer providing investment services in
connection with the Traditional IRA Custodial Account.
c. "Code" means the Internal Revenue Code of 1986, as amended.
d. "WFCS" means Wells Fargo Clearing Services, LLC in its capacity as Custodian, its successors,
permitted assigns, and any affiliated organization, all acting in a custodial capacity.
e. "Introducing Firm" means each broker-dealer who has entered into an agreement with WFCS pursuant to
which WFCS, as agent for such broker-dealer, is contractually assigned the responsibility for the
performance of certain back office, trade processing and custody, books and records and margin credit
functions.
f. "Participant" means the Depositor, and after the Depositor’s death, the Beneficiary. For investment
purposes under Article VIII, paragraph 5, Participant shall also include the Depositor’s or Beneficiary’s
legal representative or one to whom he has granted a valid power of attorney on a form acceptable to
Custodian.
g. "Spouse" or "spouse" means the person lawfully married to the Depositor. The Depositor’s surviving
Spouse is the Spouse remaining or deemed by law to remain alive after the Depositor’s death.
2. Resignation of Custodian/Designation of New Custodian.
a. The Custodian may resign as custodian of the IRA upon giving at least thirty (30) days prior written notice
to the Participant. Prior to its resignation, the Custodian may, but shall not be required to appoint a
successor custodian. If the resigning Custodian does not appoint a successor custodian or if the
Participant does not consent to such appointment, the Participant shall, prior to the effective date of such
resignation, appoint a successor custodian to receive funds held in the IRA and deliver evidence to the
Custodian of the acceptance of such appointment by such successor. The Custodian shall then deliver
the balance held in the IRA to its successor, or to the Participant for his delivery to its successor, on the
effective date of the resignation or as soon thereafter as practical. In the event that the Participant shall
fail or refuse to appoint a successor custodian during such thirty (30)-day period, the Custodian may
make distribution directly to the Participant of the balance held in the IRA. The Custodian may reserve
such funds as it deems necessary to cover any fees or charges against the IRA.

b. The Custodian may at any time and in its sole discretion appoint a successor custodian of the IRA,
provided that such successor is an affiliate of the Custodian.

c. If the Custodian is merged with or purchased (in part, including your IRA or in whole) by another
organization authorized to serve as a custodian, then that custodian may automatically become the
trustee or custodian of your Traditional IRA.

3. Distributions.
a. Discretionary Distributions. Except as provided below, distributions shall be made upon the direction of
the Participant. In its sole discretion, the Custodian may require that such direction from the Participant be
in writing. The Custodian shall be under no duty or obligation to inquire as to the propriety of any
distribution instruction, including any distribution instructions relating to the resignation of the Custodian.
Participant is solely responsible for determining whether his or her election to withdraw all or a portion of
the IRA will result in the imposition of distribution taxes. Custodian is not obligated to make a distribution
without being provided the tax identification number of the recipient.
b. Required Distributions. The Custodian shall hold each IRA separately and make distributions in
accordance with Article IV hereof and section 408(a) of the Code and the following provisions of this
Article VIII. To the extent that Article IV is not consistent with section 408(a), as amended, section 408(a)
shall be controlling.

544408 (Rev 28 - 01/22) Page 12 of 21

 If prior to April 1 of the year following the year in which the Depositor becomes age 70½, the Custodian
has not received from the Depositor a request for commencement of the distribution of the IRA or, notified
the Custodian that the Depositor will satisfy the minimum distribution requirements that apply to the IRA
from another individual retirement arrangement in accordance with paragraph 6 of Article IV, the
Depositor agrees that the Custodian may, in its sole discretion, distribute to the Depositor the required
minimum payment based on the Uniform Life Expectancy Table published by the IRS. The Depositor
agrees that the Custodian is not obligated to make such payment and will not be liable for any taxes
related to failure to take the required distribution. In its sole discretion, the Custodian may require that
Depositor’s request be in writing.
c. Distributions on Death. If the Depositor dies prior to the commencement of distributions to him the
balance in the IRA shall be distributed, applied or held in accordance with Article IV of the IRA pursuant to
the request of the Beneficiary. If the Custodian does not receive such a request within ninety (90) days
after it receives written notice of the Depositor’s death, it may distribute the balance in the IRA to his
Beneficiary in a single lump sum payment. The Beneficiary agrees that the Custodian is not obligated to
make such payment. In its sole discretion, the Custodian may require that the Beneficiary’s request be in
writing.
If the sole Beneficiary is the Depositor’s surviving spouse, the surviving spouse may elect to treat the IRA
as the spouse’s IRA. The foregoing election will be deemed to have been made if the surviving spouse
contributes to the IRA, makes a rollover contribution to or from the IRA or fails to elect to receive a
distribution by December 31 of the calendar year that contains the first anniversary of the Depositor’s
death or otherwise in accordance with Article IV or paragraph (e) hereof.
d. Payments to Children. If a distribution upon the death of the Depositor is payable to a person known by
the Custodian to be a minor or otherwise under a legal disability, the Custodian may, in its absolute
discretion, make all, or any part of the distribution to such other person as may be acting as a parent of
such Beneficiary or legal guardian, committee, conservator, trustee or other legal representative,
wherever appointed, of such Beneficiary and the receipt by such person shall be a full and complete
discharge by the Custodian of any sum so paid.
e. Annuity Payments. Notwithstanding anything in Article IV3(b) or (c) to the contrary, no distribution in the
form of an annuity shall be made hereunder.

4. Beneficiary.
The Depositor shall designate in writing the person or persons (or entity or entities) to receive any distribution to be
made by reason of the Depositor’s death. Each such designation shall be filed with the Custodian in a form
acceptable to the Custodian and may be changed from time to time by the Depositor filing a new written designation
with the Custodian. The Custodian reserves the right to limit the number of Beneficiaries or other directions
designated on your IRA. A Beneficiary is subject to and bound by all the terms and conditions of the Traditional IRA
Custodial Agreement and Disclosure Statement. A Beneficiary is required to complete and submit any and all forms
deemed necessary by the Custodian in order to process a transaction such as a distribution or transfer.
If you invest all or a portion of his or her IRA in an annuity, the annuity is an investment within the IRA. If the
Depositor invests all or a portion of his or her IRA in an annuity, then his or her account balance of the annuity will be
paid in accordance with either the beneficiaries the Depositor designates on his or her IRA or the default beneficiary
provisions of this Agreement. When an annuity is held in your IRA, a spouse beneficiary may have spousal rights (i.e.
spousal continuation) that he or she may be able to exercise upon your death. If you designate a non-spouse
beneficiary (someone other than your spouse) upon your death any annuity will be liquidated. The annuity carrier will
transfer the proceeds to your IRA to be distributed in accordance with the beneficiary designation on file with us.
If a designated beneficiary (including any contingent beneficiary) does not survive the Depositor, such beneficiary’s
interest shall lapse, and the percentage interest of any remaining beneficiary (including any contingent beneficiary)
shall be increased on a pro rata basis unless the Depositor’s beneficiary designation provides otherwise.

If you have more than one beneficiary who is entitled to benefits from your account after you die, each beneficiary’s
interest in your IRA will be considered to be a subaccount for purposes of determining required minimum
distributions. The distribution rules will then be applied to each beneficiary’s benefit.

In the event no designation is filed at the time of Depositor’s death, there is no surviving Beneficiary or the
Beneficiary designation is deemed illegal or otherwise prohibited by state or other law, the Beneficiary shall be the
Depositor’s surviving spouse. In the event the Depositor does not have a spouse or the Depositor’s spouse
predeceases the Depositor, the Beneficiary shall be the Depositor’s children as determined under state law. In such a
case, a legal or personal representative shall provide the Custodian a written certification listing the names of the
Depositor’s surviving children. If there is no legal or personal representative, a court order may be required. Under
the foregoing circumstances, if the Depositor is not survived by children as determined under state law, the Custodial
Account shall be paid to the Depositor’s estate.
The Custodian may pay to the Depositor’s surviving spouse such amount of the Traditional IRA to which he or she
demonstrates to the satisfaction of the Custodian that he or she is entitled under marital or community property laws
to the extent that the Depositor has not designated the Depositor’s surviving spouse to receive such amount as a
beneficiary, unless the Depositor’s spouse has properly consented in writing otherwise. The Depositor understands
that we may reasonably delay payment to the Depositor’s beneficiaries to the extent necessary for us to determine
544408 (Rev 28 - 01/22) Page 13 of 21
whom to pay and the proper amounts. It is the Depositor’s responsibility to determine whether such laws apply and to
request the Depositor’s spouse to consent to the Depositor’s beneficiary designation if appropriate. The Depositor
understands that we are not responsible if a payment has been made in good faith to a party other than the
Depositor’s surviving spouse and that the Depositor’s surviving spouse may not recover such amount paid from us.
In the event that the Depositor names his or her spouse as Beneficiary of the IRA, the following provisions apply:
• If a Depositor designates his spouse as Beneficiary and there is a subsequent divorce, the ex-spouse will be
treated like any beneficiary that predeceases the Depositor; this change may be overruled by court order (such
as if the divorce decree requires that the ex-spouse remain as beneficiary);
• If the ex-spouse is designated as Beneficiary AFTER the effective date of the divorce, he or she will remain as
Beneficiary for the IRA, subject to surviving Depositor; this change may be overruled by court order (such as if
the divorce decree requires that the ex-spouse be removed as Beneficiary); and
• The Custodian shall be released and held harmless in the event that we are not notified of the divorce prior to
making payment and therefore pays to the ex-spouse.
Unless a designation filed by the Depositor and agreed to by the Custodian states otherwise, if the Beneficiary dies
after the Depositor, including the time before the determination date (September 30 in the year following the year of
death of the Depositor) the beneficiary will be the person, persons, legal entity or entities designated by the
Beneficiary. Such designation shall be filed with the Custodian on a form acceptable to the Custodian. In the event no
designation is filed at the time of the Beneficiary’s death or there is no surviving beneficiary designated by the
Beneficiary, the beneficiary shall be the Beneficiary’s surviving spouse. In the event that the Beneficiary does not
have a surviving spouse, the beneficiary shall be the Beneficiary’s children as determined under state law. In such a
case, a legal or personal representative shall provide the Custodian a written certification listing the names of the
Beneficiary’s surviving children. If there is no legal or personal representative, a court order may be required. Under
the foregoing circumstances, if the Beneficiary is not survived by children as determined under state law, the
beneficiary shall be the Beneficiary’s estate.
5. Investments.
a. Participant Direction. The IRA shall be invested, as instructed by the Participant, in one or more of the
investment options made available by Broker and permitted in accordance with Subsection (b) hereof. Such
investments shall be subject to the terms and conditions of this Agreement and in the relevant new account
documents. All investment directions shall be given in a form that complies with the reasonable requirements
and procedures imposed by the Custodian. Such requirements may include that certain representations and
warranties and agreements accompany such directions, including indemnification. The Participant may
designate someone else to direct the investment of the assets of the IRA by executing a valid third party
trading authorization or power of attorney on a form acceptable to the Custodian and by naming a person or
entity acceptable to the Custodian.
We shall not be liable for any loss, liability, or penalty, which results from Participant’s (or his or her duly
authorized representative’s) exercise of control (whether as a result of action or inaction) over the IRA.
b. Permitted Investments. Investments may be made in instruments and investment vehicles that are
permitted by the Custodian and are compatible with its administrative and operational requirements. The
Custodian or its affiliates shall not be liable for any liabilities, including tax liabilities, resulting from
investments not compatible with its administrative and operational requirements. The Custodian, at its
discretion, may refuse to hold any investment or investment type, including, but not limited to, gold, silver and
platinum coins issued under the laws of any state and bullion. The Custodian also has the right to refuse to
accept any transfer or rollover of assets other than cash.
The Custodian will not be liable for failure to notify the Participant of any corporate actions regarding
securities held in the IRA that are not provided by any service to which the Custodian subscribes. The
Participant also agrees that the Custodian shall have no duty to forward to the Participant any class action
lawsuit or other legal information unless compensated by the parties to the legal action for research and
distribution expenses.
The Participant acknowledges and agrees to arbitrate controversies as described in other account opening
documents.
c. Investment Powers.
i. The Custodian may delegate and/or assign to one or more corporations, entities or persons, whether or
not affiliated with the Custodian, the performance of record keeping and other ministerial services in
connection with the IRA.
ii. The Custodian may appoint one or more sub-custodians that may include affiliates of the Custodian.
iii. The Custodian may hold property in nominee name, in bearer form, or in book entry form, in a
clearinghouse corporation or in a depository (including an affiliate of the Custodian).
iv. If made available, assets of the IRA may be invested in deposits of Wells Fargo Bank, N.A. (or an
affiliate) that bear a reasonable rate of interest.
v. If made available, assets of the IRA may be invested in any common or collective trust fund or common
investment fund maintained by Wells Fargo Bank, N.A. or its affiliate and the provisions of the document
that govern any such fund, as amended, are hereby incorporated.

544408 (Rev 28 - 01/22) Page 14 of 21

 d. Voting. The Custodian shall follow Participant’s (or his or her duly authorized representative’s) written
instructions for voting shares and exercising other rights of ownership for investments held in the IRA. In
absence of direction, the Custodian will not exercise any rights and will not be responsible for failing to take
action.
e. Investment Advisory Services. Participant may enter into an agreement with Custodian, its affiliates, or
Introducing Firm to provide investment advisory services and any services provided thereunder will be
subject to the terms of such agreement.
f. Use of Introducing Firm. If you open your account through an Introducing Firm, you agree that, unless
otherwise prohibited by law, any benefits, rights or protections of the Custodian under this Agreement are
extended to and may be exercised by, or assigned to, the Introducing Firm and may be enforced
independently or jointly by the Custodian and/or the Introducing Firm.
6. Taxes.
The Custodian shall have the power and right to pay from the IRA any estate, inheritance, income or other taxes, and
any interest or penalties assessed or levied with respect to the IRA or the Participant’s interest therein. The
Custodian may liquidate assets held in the IRA for taxes withheld or assessed against the IRA. The Custodian is not
obligated to liquidate assets and is not responsible for any tax liabilities if assets are liquidated or if they are not
liquidated.
The Participant by signing the IRA enrollment/application form and under penalties of perjury certifies that:
a. The social security number shown on the IRA enrollment/application form along with any other account
opening forms is the Participant’s correct taxpayer identification number.

b. The Participant is not subject to backup withholding because (1) the Participant is exempt from backup
withholding, or (2) the Participant has not been notified by the IRS he or she is subject to backup withholding
as a result of failure to report all interest or dividends, or (3) the IRS has notified the Participant that he or she
is no longer subject to backup withholding. Or, the Participant has notified the Custodian in writing that he or
she is subject to backup withholding.

7. Excess Contributions.
If the Depositor determines that any part or all of the contribution to the IRA for any taxable year is an excess
contribution as defined in section 4973(b) of the Code, he or she may give the Custodian a written request for the
refund of the amount of the excess contribution for such taxable year. Upon receiving such request the Custodian
shall refund the requested amount.
8. Amendment.
Subject to the provisions of Article VII, the Custodian may amend the provisions of the IRA at any time by giving
written notice of the amendment to the Participant. The Participant is deemed to have automatically consented to any
amendment unless the Participant notifies the Custodian in writing that the Participant does not consent to the
amendment and provides written notice of the IRA termination within 30 days after the Custodian sends a copy of the
amendment to the Participant. Any and all amendments made to comply with any changes in applicable laws or
regulations shall not require the Participant’s consent.
9. Termination.
The IRA shall terminate when the Custodian receives written instructions from the Participant to transfer all of the
assets of the IRA to the trustee or custodian of another retirement plan or directly to the Participant or upon the
distribution of all of the assets of the IRA in accordance with Article IV hereof. In order for the Participant to transfer
all of the assets of the IRA, the Participant must give the Custodian written instructions to make the transfer at least
fifteen (15) days prior to the date the transfer is to be made. If the Custodian is notified by the Commissioner of the
Internal Revenue Service that another custodian must be substituted for the Custodian because the Custodian has
failed to comply with the requirements of Treasury regulation section 1.408-2(e) or is not keeping the records, making
returns or rendering statements as required by the Internal Revenue Service’s forms or regulations, the Custodian
will substitute another custodian and will notify the Participant of this fact. The Participant agrees upon such
notification or upon notification from the Commissioner of the Internal Revenue Service to transfer the Participant’s
assets to another individual retirement account or to substitute another custodian for the Custodian. The Custodian
shall not be liable for any actions or failures to act on the part of any successor custodian or trustee nor for any tax
consequences resulting for the transfer or distribution of assets pursuant to this section.
The Participant may not receive interest or dividends that have accrued but that have not been credited on a
terminated IRA. A quarterly minimum balance fee of up to $10 (or the balance of the account if less than $10) may
apply if your balance falls below $50. If the fee should bring your account to a zero balance, the Custodian may
terminate your IRA.

544408 (Rev 28 - 01/22) Page 15 of 21

10. General Provisions.
The following general provisions apply to this Agreement.
a. Non-Assignable Interests. The Participant shall not have any right to pledge any part of the IRA as security
for a loan or to assign, transfer or in any way create a lien on the IRA or any payments to be made under this
IRA. Any indemnification agreement, cross-collateralization agreement or other grant of a security interest in
favor of the Custodian or its affiliates, in any other agreement the Participant may have with us, as set forth in
any other agreement, which guarantees the payment of debits to (or by) the Custodial Account under this
Agreement by (or to) a Related Account is hereby null, void, and unenforceable with respect to the Custodial
Account under this Agreement, notwithstanding any contrary provisions in the Related Account agreement.
For this paragraph, a “Related Account” is another account established with us where such account is
subject to an agreement with us that also covers the Custodial Account and /or guarantees the payment of
debits to the Plan Account. This paragraph shall be interpreted in a manner consistent with the Department
of Labor’s Prohibited Transaction Class exemption 80-26 and shall not limit our ability to seek any and all
legal remedies against you with regard to any indebtedness.

The IRA shall not be subject to any execution, attachment, assignment, garnishment or other legal process
by any creditor of the Participant except to the extent allowed by applicable law. Notwithstanding the
foregoing, all or a portion of the Participant’s interest may be transferred to the Participant’s former spouse
pursuant to a valid divorce decree, incorporated property settlement agreement or agreement of legal
separation. Any interest so transferred shall be treated as an IRA for the benefit of the former spouse and
such spouse shall be treated as the Depositor of such IRA. Custodian may require any additional instruction
it deems reasonable and necessary to accomplish the transfer. The Custodian, nor its affiliates, will not be
liable for any adverse consequences resulting from such transfer.

b. Construction. If any part of the agreements governing this account is held to be illegal or invalid, the
remaining parts shall not be affected. Neither the Participant’s nor the Custodian’s failure to enforce at any
time or for any period of time any of the provisions of the governing agreements constitutes a waiver of such
provisions, or the rights of either party to enforce each and every provision thereafter. The Participant further
agrees to be bound by the regulations of the Custodian or any governmental agency regarding the operation
of this IRA or any investment held hereunder.

c. Gender. Wherever in the language of this IRA the masculine gender is used, it shall be deemed equally to
refer to the feminine gender.

d. Commissions, Expenses and Fees.

i. All expenses incurred in connection with the administration of the IRA, including fees for legal services,
and such reasonable compensation to the Custodian as may be established by the Custodian, may be
paid from the IRA by the Custodian. Reimbursement for any expenses shall be due and payable upon
demand. When the Custodial Account is established, the Participant will be furnished with a schedule of
fees/fee notice and thereafter will give the Participant written notice of any changes in that schedule.
Other fees and expenses incurred due to the management of the IRA, including but not limited to
investment advisory fees, may also be paid from the IRA by the Custodian at the direction of the
Participant.

ii. All annual fees for a calendar year shall be due and payable when invoiced. The Custodian may charge
any annual fees previously disclosed without any further notification to the Participant. In the event that
the IRA is terminated or transferred, a termination and/or transfer fee and any outstanding annual fees
(including the current year’s annual fee) shall be due and payable on the date of the termination or
transfer. The Custodian may liquidate assets held in the IRA to make withdrawals, distributions or
transfers or pay fees, expenses, liabilities, charges or taxes assessed against the IRA. The Custodian is
not obligated to liquidate assets and is not responsible for any tax liabilities if assets are liquidated or if
they are not liquidated.

iii. The Custodian, or an affiliate, may retain any interest earned on assets awaiting investment or
disbursement. You understand and agree that this interest (generally referred to as "float") will be retained
by us as additional compensation for the provision of services with respect to your Traditional IRA. Such
interest shall generally be a prevailing interest rate.

Assets awaiting investment include (a) new deposits to the Traditional IRA, including interest and
dividends, and (b) any uninvested assets held by the Traditional IRA caused by an instruction to us to
purchase or sell securities where investment instructions are received too late in the day to be completed.
We may also earn float on distributions from the time funds are distributed from the IRA until the check is
cashed or other payment method is completed.
e. Reports. The Participant agrees to provide information to the Custodian at such time and in such manner as
may be necessary to prepare any reports required pursuant to the Code and the regulations thereunder. The
Participant agrees to hold the Custodian harmless against any liability arising from any inaccuracies or
omissions with respect to such information.
544408 (Rev 28 - 01/22) Page 16 of 21
 f. No Representations. The Participant shall not rely on any oral or written representations of the Custodian,
its agents, affiliates, officers, directors, and employees as to the tax or other effect of any transaction relating
to the IRA.

g. Power of Attorney. The Participant may designate one or more individuals to act as the Participant’s
attorney-in-fact. Such written designations shall be made in a manner acceptable to the Custodian. The
Custodian may rely on such designation until the Custodian has received written notification to the contrary.
The Custodian shall be under no liability for any loss of any kind occasioned by its actions in accordance with
the directions of the Participant’s attorney-in-fact, and shall be under no duty to question any direction of the
Participant’s attorney-in-fact.

Payments from the IRA may be made at our discretion to the Participant’s duly authorized or qualified legal
representative, including without limitation, legal guardian, committee or attorney-in-fact, during any period
that the Participant is incapable of executing a valid receipt for such payments. Any payment made pursuant
to the provisions of this paragraph shall be a complete discharge of any liability for the making of such
payment from the IRA.

The Custodian may, at its sole discretion, prohibit any transaction and/or acts requested by the attorney-in-
fact.
h. Authority to Contract. The Participant acknowledges that this document and any accompanying
documents constitute a contract between the Participant and the Custodian. By entering into this contract,
the Participant agrees that he or she has full legal power and authority to enter into any transaction with or
through the Custodian and to provide instructions related to the IRA. The Participant agrees to promptly
notify the Custodian in writing if their authority described above materially changes. The Participant agrees to
be bound by any and all rules and regulations of the Custodian or any government agency regarding the
operation of the IRA or any investment held hereunder.

i. Effective Date. The effective date shall be the date that the Custodian accepts the Depositor’s IRA
enrollment/application form.

j. Notice. Notices to us concerning the IRA must be in writing and must be delivered in person or sent by
registered or certified mail to the mailing address specified in Question A2 of the Disclosure Document, as
that address may be changed from time to time, or to any other address specified by us. We may honor any
instructions in writing from the Participant sent by mail yet shall not be responsible for failure to follow any
instructions not sent by certified or registered mail. Notices from us shall be in writing and sent to the
Participant’s address listed in the IRA enrollment/application form (or most current address of record), or
other address specified by the Participant.

k. Extraordinary Events. The Participant agrees that the Custodian and its affiliates shall not be liable for any
loss or delay caused directly or indirectly by government restrictions, exchange or market rulings, suspension
of trading, war, acts of terrorism, strikes, failure of the mail or other communication systems, mechanical or
electronic failure, failure of third parties to follow instructions, or other conditions beyond the control of the
Custodian.

11. Sharing Information.

The Participant expressly agrees that the Custodian is authorized to share such IRA information which it may lawfully
share with its affiliated entities, including Broker, for such purposes as the Custodian, in its sole discretion, may deem
necessary or appropriate.
The Custodian or its agent may submit the Participant’s name, address, and security positions to the agent of the
issuer of the securities held in the name of the Participant or to the Custodian’s agent for corporate communications
unless we receive written notification from the Participant to the contrary.
12. Limitations on Custodial Liability and Indemnification.
The Participant and the Custodian intend that the Custodian shall have and exercise no discretion, authority, or
responsibility as to any investment in connection with the IRA and the Custodian shall not be responsible in any way
for the purpose, propriety, or tax treatment of any contribution, or of any distribution, or any other action or inaction
taken pursuant to the Participant’s (or his or her duly authorized representative’s) direction. Participant agrees that
the acceptance of any contribution by us is not an opinion that any party will be entitled to a tax deduction or
"rollover" treatment on such amount. Participant understands that the Custodian has no responsibility or obligation to
calculate the amount of any distribution or to make any election for the Participant. The Participant shall bear sole
responsibility for the suitability of any investment and for any adverse consequences arising from such an investment,
including, without limitation, the inability of the Custodian to value or to sell an investment, or the generation of
unrelated business taxable income with respect to an investment. To the fullest extent permitted by law, the
Participant shall at all times fully indemnify and hold harmless the Custodian and its agents, affiliates, successors,
and assigns and its officers, directors, and employees, from any and all liability arising from the Participant’s (or his or
her duly authorized representative’s) investment direction under this IRA and from any and all other liability
whatsoever which may arise in connection with this IRA, except liability arising under applicable law or liability arising

544408 (Rev 28 - 01/22) Page 17 of 21

from the gross negligence or willful misconduct on the part of the indemnified person.
The Custodian will be responsible only for the cash and property actually received by it under the terms of the IRA
and will not be responsible for the collection of contributions to the IRA. Establishment of or subsequent contribution
to this IRA is not intended to be a transfer or gift under any state Uniform Transfers to Minors Act or any comparable
act under the laws of any state which may have jurisdiction over this IRA. Our only duties and responsibilities with
respect to the IRA shall be those specifically set forth in this IRA.
13. Recording Conversations.
The Participant understands and agrees that the Custodian and the Broker may electronically record any of the
Participant’s telephone conversations with the Custodian or the Broker. The Participant waives all rights to object to
the admissibility into evidence of such recording in any legal or other proceeding between the Participant and the
Custodian, its employees or affiliates, or in any proceeding brought by an exchange or governmental agency to which
the Custodian, its employees or affiliates, are party or in which records are subpoenaed.
14. Holding Account Assets.
The Participant hereby authorizes us to comply with any process, summary, order, injunction, execution, distribution,
levy, lien, or notice of any kind ("Process") received by or served upon us which in our sole opinion affects the IRA.
The Participant authorizes us to, at its option and without liability, thereupon refuse to honor orders to pay or
withdraw monies from the IRA and to either hold the balance therein until the Process is disposed of to our
satisfaction, or to pay the balance over to the source of the Process. In any event, we shall have no obligation to
contest the service of any such Process, or the jurisdiction of said service. The Custodian may also require additional
clarification or support for any court order or other document if it deems that the terms or effectiveness of the order or
document are unclear. In any event, the Custodian shall have no obligation to contest the service of any such
Process, or the jurisdiction of said service. In addition, the Custodian has a right to freeze or hold an account balance
in the event that it believes that ownership of the account or any proceeds therein are in dispute and may continue to
hold or freeze the account until the dispute is resolved to its satisfaction.

If the Custodian is unable to make a distribution to the appropriate party within 6 months after such distribution is to
be made because we are unable to contact the Participant by mailing to the most recent address provided to us by
the Participant for purposes of the IRA, the Custodian may, without liability for so doing, sell any securities in the IRA
and, subject to applicable limitations, deposit the proceeds and any other funds in a bank deposit or a money market
mutual fund, as designated by us from time to time, until such time as disbursement is possible to the appropriate
party or until such funds escheat to a governmental agency by operation of law.
15. Counterparts.
The IRA enrollment/application form may be executed in any number of counterparts, each one of which shall be
deemed to be the original although the others have not been produced.

Section III: Additional Information

A. Periodic Statements For Your IRA Investment Options.
You will receive a periodic statement reflecting all of the investments in your IRA. In addition, you will receive a
statement reflecting activity following any month in which there is activity in your IRA.
If you have questions about your IRA statement, please contact us. You must notify us within 10 days in writing of
any discrepancies noted on your statement, otherwise the statement will be deemed correct and conclusive.
B. How to Determine Your Annual Contributions to Date.
To determine the amount you have contributed to your IRA at any point in time, you should refer to your statement.
Each statement will include a total of contributions made during that calendar year.
C. Tax Reporting.
Any discrepancies or errors in any tax reporting by the Custodian must be reported to the Custodian within 60 days
after the reporting is mailed by the Custodian to the Participant.

544408 (Rev 28 - 01/22) Page 18 of 21

 DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224

July 1, 2003

Wachovia Securities LLC

901 East Byrd Street
Richmond, VA 23219

EIN Number: 34-1542819

Ladies and Gentlemen:

In a letter dated March 21, 2003, as supplemented by a facsimile transmitted on June 23, 2003, your authorized representative
requested a written notice of approval that Wachovia Securities LLC may act as a nonbank custodian of medical savings accounts
established under section 220 of the Internal Revenue Code, plans qualified under section 401, accounts described in section
403(b)(7), individual retirement accounts (IRAs) established under sections 408, 408A (dealing with Roth IRAs), and 530 (dealing
with Coverdell education savings accounts), and eligible deferred compensation plans described in section 457(b).

Section 220(d)(1)(B) of the Code (dealing with Archer MSAs (medical savings accounts)) provides, in pertinent part, that the
trustee of a medical savings account must be a bank (as defined in section 408(n)), an Insurance company (as defined in section
816), or another person who demonstrates to the satisfaction of the Secretary that the manner in which such person will
administer the trust will be consistent with the requirements of this section. Q & A-10 of Notice 96-53, 1996-2 C.B. 219 provides, in
pertinent part, that persons other than banks, insurance companies, or previously approved IRA trustees or custodians may
request approval to be a trustee or custodian in accordance with the procedures set forth in section 1.408-2(e) of the Income Tax
Regulations.

Section 401(f)(1) of the Code provides that a custodial account shall be treated as a qualified trust under this section if, such
custodial account would, except for the fact it is not a trust, constitute a qualified trust under this section. Section 401(f)(2)
provides that the custodian must be a bank (as defined in section 408(n)) or another person who demonstrates to the satisfaction
of the Secretary that the manner in which such other person will hold the assets will be consistent with the requirements of section
401 of the Code. Section 401(f) also provides that in the case of a custodial account treated as a qualified trust, the person holding
the assets of such account shall be treated as the trustee thereof.

Section 403(b)(7)(A) of the Code requires, in part, that for amounts paid by an employer to a custodial account to be treated as
amounts contributed to an annuity contract for his employee, the custodial account must satisfy the requirements of section 401(f)
(2). That section also requires, in order for the amounts paid by an employer to be treated as amounts contributed to an annuity
contract for his employee, that the amounts are to be invested in regulated investment company stock to be held in the custodial
account and under the custodial account no such amounts may be paid or made available to any distributee before the employee
dies, attains age 59 1/2, has a severance from employment, becomes disabled (within the meaning of section 72(m)(7)), or in the
case of contributions made pursuant to a salary reduction agreement (within the meaning of section 3121(a)(1)(D)), encounters
financial hardship.

Section 408(h) of the Code provides that a custodial account shall be treated as a trust under this section if the assets of such
account are held by a bank (as defined in subsection (n)) or another person who demonstrates to the satisfaction of the Secretary
that the manner in which such other person will administer the account will be consistent with the requirements of this section, and
if the custodial account would, except for the fact that it is not a trust, constitute an IRA described in subsection (a). Section 408(h)
also provides that, in the case of a custodial account treated as a trust by reason of the preceding sentence, the custodian of such
account shall be treated as the trustee thereof.

Section 408A of the Code provides, in general, that a Roth IRA shall be treated in the same manner as an individual retirement
plan. Section 7701(a)(37)(A) defines an individual retirement plan as an individual retirement account described in section 408.

544408 (Rev 28 - 01/22) Page 19 of 21

Section 530(g) of the Code (dealing with Coverdell education savings accounts) provides that a custodial account shall be treated
as a trust if the assets of such account are held by a bank (as defined in section 408(n)) or another person who demonstrates, to
the satisfaction of the Secretary, that the manner in which he will administer the account will be consistent with the requirements of
this section, and if the custodial account would, except for the fact that it is not a trust, constitute an account described in
subsection (b)(1). For purposes of title 26 of the Code, in the case of a custodial account treated as a trust by reason of the
preceding sentence, the custodian of such account shall be treated as the trustee thereof.

Section VII of Notice 98-8, 1998-1 C.B. 355 (guidance relating to the requirements applicable to eligible deferred compensation
plans described in section 457(b) of the Code), provides, in pertinent part, that for purposes of the trust requirements of section
457(g)(1 ), a custodial account will be treated as a trust if the custodian is a bank, as described in section 408(n), or a person who
meets the nonbank trustee requirements of section VIII of this notice, and the account meets the requirements of section VI of this
notice, other than the requirement that it be a trust. Section VIII provides that the custodian of a custodial account may be a
person other than a bank only if the person demonstrates to the satisfaction of the Commissioner that the manner in which the
person will administer the custodial account will be consistent with the requirements of section 457(g)(1 ) and (g)(3) of the Code.
To do so, the person must demonstrate that the requirements of paragraphs (2)-(6) of section 1.408-2(e) of the regulations relating
to nonbank trustees will be met.

The Income Tax Regulations at section 1.408-2(e) contain the requirements that such other person must comply with in order to
act as trustee or custodian, for purposes of sections 220, 401(f), 403(b)(7), 408(a)(2), 408(h), 408(q), 408A, 457(b) and 530 of the
Code. One of the requirements of section 1.408-2(e) states that such person must file a written application with the Commissioner
demonstrating, as set forth in that section, its ability to act as a trustee or custodian.

Based on all the information submitted to this office and all the representations made in the application, we have concluded that
Wachovia Securities LLC meets the requirements of section 1.408-2(e) of the regulations and, therefore, is approved to act as a
nonbank custodian of medical savings accounts established under section 220 of the Internal Revenue Code, plans qualified
under section 401, accounts described in section 403(b)(7), individual retirement accounts (IRAs) established under sections 408,
408A (dealing with Roth IRAs), and 530 (dealing with Coverdell education savings accounts), and eligible deferred compensation
plans described in section 457(b).

This letter authorizes Wachovia Securities LLC to act as a passive or non-passive nonbank custodian. When Wachovia Securities
LLC acts as a passive nonbank custodian (within the meaning of section 1.408-2(e)(6)(i)(A) of the regulations), it is authorized
only to acquire and hold particular investments specified by the custodial agreement. It may not act as a passive custodian if
under the written custodial agreement it has discretion to direct investments of the custodial funds.

Wachovia Securities LLC may not act as a custodian unless it undertakes to act only under custodial agreements that contain a
provision to the effect that the grantor is to substitute a trustee or another custodian upon notification by the Commissioner that
such substitution is required because Wachovia Securities LLC has failed to comply with the requirements of section 1.408-2(e) of
the regulations or is not keeping such records, or making such returns or rendering such statements as are required by forms or
regulations. For example, one such form is Form 990-T for IRAs that have $1000 or more of unrelated business taxable income
that is subject to tax by section 511(b)(1) of the Code.

Wachovia Securities LLC is required to notify the Commissioner of Internal Revenue, Attn: T:EP:RA, Internal Revenue Service,
Washington, D.C. 20224, in writing, of any change which affects the continuing accuracy of any representations made in Its
application. Further, the continued approval of Wachovia Securities LLC to act as a nonbank custodian of medical savings
accounts established under section 220 of the Internal Revenue Code, plans qualified under section 401, accounts described in
section 403(b)(7), individual retirement accounts (IRAs) established under sections 408, 408A (dealing with Roth IRAs), and 530
(dealing with Coverdell education savings accounts), and eligible deferred compensation plans described in section 457(b) is
contingent upon the continued satisfaction of the criteria set forth in section 1.408-2(e) of the regulations.

This approval letter is not transferable to any other entity. An entity that is a member of a controlled group of corporations, within
the meaning of section 1563(a) of the Code, may not rely on an approval letter issued to another member of the same controlled
group. Furthermore, any entity that goes through an acquisition, merger, consolidation or other type of reorganization may not
necessarily be able to rely on the approval letter issued to such entity prior to the acquisition, merger, consolidation or other type
of reorganization. Such entity may have to apply for a new notice of approval in accordance with section 1.408-2(e) of the
regulations.

544408 (Rev 28 - 01/22) Page 20 of 21

This letter constitutes a notice that Wachovia Securities LLC may act as a nonbank custodian of medical savings accounts
established under section 220 of the Internal Revenue Code, plans qualified under section 401, accounts described in section
403(b)(7), individual retirement accounts (IRAs) established under sections 408, 408A (dealing with Roth IRAs), and 530 (dealing
with Coverdell education savings accounts), and eligible deferred compensation plans described in section 457(b) and does not
bear upon its capacity to act as a custodian under any other applicable law. This is not an endorsement of any investment. The
Internal Revenue Service does not review or approve investments.

This notice of approval is effective as of the date of this letter and will remain in effect until withdrawn by Wachovia Securities LLC
or revoked by the Service. This notice of approval does not authorize Wachovia Securities LLC to accept any fiduciary account
before this notice becomes effective.

In accordance with the power of attorney on file in this office, this letter is being sent to your authorized representative.
If you have any questions, please contact Mr. C. Thompson (Badge No. 50--07262) at (202) 283-9596.

Sincerely,

Donzell H. Littlejohn, Acting Manager

Employee Plans Technical Group 1

544408 (Rev 28 - 01/22) Page 21 of 21

Wrap Fee Brochure for
Intuitive Investor® Program

801 - 37967

Investment Advisory Services of Wells Fargo Advisors

Revised May 2022

One North Jefferson, St. Louis, MO 63103

Phone (314) 875-3000

wellsfargoadvisors.com

This wrap fee brochure provides information about the qualifications and business practices of
Wells Fargo Advisors and our Intuitive Investor Program (the "Program"). This information should be
considered before becoming a Client of this Program. If you have any questions about the Program or
the contents of this brochure, please contact us at (855) 283-5567.
This information has not been approved or verified by United States Securities and Exchange
Commission or by any state securities authority. Additional information about Wells Fargo Advisors also
is available on the SEC’s website at adviserinfo.sec.gov.
The advisory services described in this brochure are not insured or otherwise protected by the U.S.
Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other
government agency and involve risk, including the possible loss of principal.

Investment and Insurance Products are:

• Not Insured by the FDIC or Any Federal Government Agency
• Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate
• Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested

Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC (WFCS), Member SIPC, a registered broker-dealer and
non-bank affiliate of Wells Fargo & Company. WellsTrade brokerage accounts are offered through WFCS.

593718 (Rev 16 - 05/22) Page 1 of 23

Summary of Material Changes
Material Changes to the Wrap Fee Brochure for the Intuitive Investor Program since March 31, 2022:

• The minimum initial Account value required to open an Account has been lowered to $500.
• The Sustainability Focused portfolios have been added to the Program.
• The Tax-Loss Harvesting section of this document has been updated to indicate that the replacement Program funds
that the Manager recommends may not align with the investment approach that you have selected for your account.
• The Client Restrictions and Instructions section of this document has been updated to remove the sentence "Each of
the asset classes in our model portfolios has three ETFs assigned to it."
• The Methods of Analysis, Investment Strategies and Risk of Loss section of this document has been updated to
include information about both portfolio series now offered within the Program. Information has also been added to
describe the Risks Associated with Sustainability Focused Investing.
• The Program Website Tool Methodology section of this document has been updated to indicate that once a
recommended investment objective is provided, that Clients have the option to accept that recommendation or move one
step lower or one step higher on our risk scale. In addition, once an investment objective is selected, Clients will then
have the option to select a portfolio from either our Globally Diversified series or from our Sustainability Focused series.
• The Brokerage Practices section of this document has been updated to include information specific to Fractional
Shares.

593718 (Rev 16 - 05/22) Page 2 of 23

Table of Contents
Page

Summary of Material Changes 2

Services, Fees and Compensation 4
The Intuitive Investor Program Services 4
Program Fees 6
Compensation 8
Account Termination 9
Account Requirements and Types of Clients 9
Portfolio Manager Selection and Evaluation 10
Services Tailored to Individual Client Needs 10
Client Restrictions and Instructions 11
Performance-Based Fees and Side-By-Side Management 11
Methods of Analysis, Investment Strategies and Risk of Loss 11
Program Website Tool Methodology 12
Proxy and Reorganizations 13
Client Information Provided to Portfolio Managers 14
Client Contact with Portfolio Managers 14
Additional Information 14
Disciplinary Information 14
Other Financial Industry Activities and Affiliations 16
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 17
Review of Accounts 18
Prospectus Delivery 18
Client Referrals and Other Compensation 18
Brokerage Practices 18
Financial Information 23

593718 (Rev 16 - 05/22) Page 3 of 23

The Intuitive Investor Program
Overview and Definitions
Wells Fargo Advisors ("WFA") is a trade name used by Wells Fargo Clearing Services, LLC ("WFCS"). WFA is a non-bank
affiliate of Wells Fargo & Company ("Wells Fargo"), a publicly held company (NYSE: WFC) and financial holding company and
bank holding company founded in 1852. Wells Fargo and its affiliates are engaged in a number of financial businesses,
including retail brokerage and investment advisory services.
WFA is affiliated with Wells Fargo Investment Institute, Inc. ("WFII"), a registered investment adviser that provides advisory
services and research to WFA.
Helpful Terms. You, Yours, I, Client and the Account Owner is any person who has entered into an Agreement with WFA.
We, Our, Ours and Us includes Wells Fargo Clearing Services, LLC d/b/a Wells Fargo Advisors including their affiliates and
agents (collectively referred to as "Wells Fargo Advisors" or "WFA").
Account is collectively or individually any brokerage Account and/or any Advisory Program Account you have with us,
including any and all funds, money, securities and/or other property you have deposited with us.
Affiliate is any entity that is controlled by, controls or is under common control with us. Each Affiliate is a separate legal entity,
none of which are responsible for the obligations of the other.
Securities and Other Property is money, securities, financial instruments and commodities of all types and related contracts,
options, distributions, proceeds, products and accessions.
Agreement is the Agreement between you and us regarding your Account, and any other documents included by reference.
Types of Advisory Services We Offer. We offer a number of advisory Programs ("Programs") and services that are
designed to help you meet your investment objectives and goals, including various wrap fee Programs, consulting services
and financial planning services. Wrap fee Programs generally, subject to certain limitations, include advisory, execution,
custodial and reporting services for a single fee, rather than separate costs and commissions for each transaction. WFA's
advisory Programs and services include:
• Unified and Separately Managed Account Wrap Fee Programs
• Mutual Fund Advisory Wrap Fee Programs
• Financial Advisor Directed Wrap Fee Programs
• Non-Discretionary, Client Directed Advisory Wrap Fee Programs
• Institutional and Retirement Plan Consulting Services
• Financial Planning Services

About This Wrap Fee Brochure. This disclosure document specifically describes the Intuitive Investor Program.
Descriptions of the services and fees for the other advisory Programs and services we offer can be found in separate
disclosure documents, copies of which are available upon request or from www.sec.gov.

Services, Fees, and Compensation

Intuitive Investor Program Services
Description. The Intuitive Investor Program ("Program") is a digital investment advisory Program in which investment advice
is given through the Program website. Through your Account, you will be able to invest in one of several discretionary asset
allocation portfolios that are diversified across multiple asset classes. Under this Program, you will provide to us through the
Program website, mobile applications or other digital interfaces (the "Website"), information about your risk tolerance and
investment goals from which we will recommend a Portfolio.
After you have enrolled in the Program, you may be able to select or change certain services with instructions to us; however,
in certain circumstances we may ask you to sign a separate Agreement or complete additional documentation.
Electronic Relationship. In this Program, services are provided to you electronically through the use of the Program
Website and the majority of communication will be done electronically. You will need to complete the Program Agreement and
any other agreements as necessary to participate in the Program. These agreements and any required disclosures will be
delivered to you electronically. In order to access the Program Website, you will be required to establish online credentials
and provide us with a valid email address. You must notify us immediately of any changes to your email address. For any
issues with the Program Website, you may call us at (855) 283-5565. You may also contact us via phone at (855) 283-5567
for assistance and support related to Your Account including the risk tolerance questionnaire, portfolio recommendations,
Account opening, and/or Account performance.
Management of your Account. The Portfolios that we recommend are developed by WFII, adopted by WFA and
implemented by an unaffiliated Manager. The current Manager is SigFig Wealth Management, LLC. We may change the
Manager from time to time in our sole discretion without your prior consent. The Manager will exercise discretion with respect
to the day-to-day management of your Account, and provide instruction to us for execution of transactions in your Account.

593718 (Rev 16 - 05/22) Page 4 of 23

Program Assets. Program Accounts will be invested in portfolios comprised of exchange traded funds ("ETFs"). Accounts
will also maintain a cash position held in the Cash Sweep Program. For more information, please see the "Cash Sweep
Program" section, later in the Brochure.
ETFs are typically passively managed portfolios designed to track the performance of a basket of securities or a certain index.
ETFs trade on an exchange the way individual stocks do. In simplest terms, traditional ETFs are passively-managed "baskets"
of securities that are designed to closely track the performance of specific indices, market sectors, or industries. ETFs are
priced and can be bought and sold throughout the trading day.
Traditional ETFs that seek to track the performance of a specified benchmark/index are not actively managed. As a result, the
investment advisers of those ETFs do not attempt to take defensive positions in declining markets. Therefore, ETFs may be
subject to greater losses in a declining market than an actively managed fund.
ETFs may not have a high degree of correlation to its underlying index as a result of the ETFs expenses, imperfect correlation
between the ETF's investments and the components of the underlying index, rounding of shares prices, changes to the
underlying index, turnover rate, and regulatory policies.
The Program Portfolios may consist of a blend of traditional low-cost ETFs and complementary "Smart Beta ETFs." Smart
Beta ETFs seek to enhance portfolio construction by weighting underlying securities by means other than just the size of the
companies. These alternative ways to weight portfolio constituents can employ some of the same screening processes and
optimization techniques used by active managers, but with systematic approaches to track referenced benchmarks helping to
substantially reduce fund expenses in relation to fully active management.
Establishing a Program Account. In order to establish a Program Account you must complete the risk tolerance
questionnaire ("RTQ"). We will rely on the information contained in the RTQ when making investment recommendations for
your Program Account. The services provided in this Program, including any advisory recommendations we provide, are highly
reliant on the accuracy of the information you provide in the RTQ. If you provide us with inaccurate information, this could
materially impact the quality and applicability of our recommendations.
We reserve the right to refuse for any reason to open any Program Account. No Program Account shall become active until
you have provided us with the information and funds necessary to commence activity within your Program Account. Your
request to begin services under the Program Agreement is not considered a market order, since both WFA and/or the
Manager require time to process your request. We will, however, make every effort to process your request promptly.
Factors to Consider. When determining whether to open a Program Account, you should consider various factors, including
but not limited to the following:
• Your preference for advisory services or brokerage services;
• Your preference for asset-based pricing or commission-based pricing;
• Your preference for an online/digital relationship rather than a traditional relationship with a Financial Advisor;
• Your expected trade activity;
• Your preference for a discretionary rather than non-discretionary relationship;
• Your desire for investment advice and/or our management of your money;
• Your investment preferences and the types of investments available to you within one Program versus another;
• Expected levels of cash to remain uninvested; and
• The features and benefits of one service or Program versus another.

Rebalancing Services. The Manager is responsible for rebalancing the assets in your Program Account. Rebalancing will
occur when your Program Account holdings deviate from the Target Allocation of your selected portfolio, subject to certain drift
tolerance parameters. In most cases, ETF holdings may drift 25%-35% from the target allocation before rebalancing, and cash
may drift 50% from the target allocation before rebalancing. For example, if an ETF position has a target allocation of 10% of
your account value and a drift tolerance of 25%, shares would be sold if the allocation of the ETF drifted to 12.5% of your
account value or more; and, shares would be purchased if the allocation drifted to 7.5% of your account value or less. We may
alter the drift tolerance parameters in your selected Portfolio at any time, and the manager may modify at any time the manner
or frequency with which Manager calculates, generates, and places with WFA the orders to rebalance your Program Account.
The use of drift tolerance parameters results in slight differences between Accounts invested in the same portfolio. Various
factors, such as market fluctuations and the timing of withdrawals and deposits may affect how closely the assets in your
Program Account reflect the Target Allocation of your selected Portfolio. Rebalancing your Account may create tax
consequences.
Tax-Loss Harvesting. Through the Website, you may instruct us to initiate tax-loss harvesting trades in your taxable
Account. Tax-loss harvesting is not offered in trust or custodial Accounts. If such instructions are received, understand that:
• All such requests will be made on a best-efforts basis.
• The Manager may limit the amount of gains or losses that can be realized in your Account.

593718 (Rev 16 - 05/22) Page 5 of 23

 • Performance may be adversely impacted.
• When normal trading activity resumes in your Account, the same or similar securities may be repurchased, which
may generate new taxable gains or losses.
• Securities sold for a loss may not be able to be repurchased for a period of 31 days due to the Internal Revenue
Service Wash Sale Rules. This may result in a higher than normal cash position for that period or the Manager may
invest in substitute securities. Please note: wash sale rules apply to the Client and the household. Therefore, if you
sell a stock in your taxable Account and repurchase the security in your IRA within 30 days (for example), the loss
is disallowed, though the retirement Account basis is not increased.
• The replacement Program funds that the Manager recommends may not align with the investment approach that
you have selected for your account.

Please note: we do not render legal, accounting, or tax advice. Please consult your tax or legal advisors before taking any
action that may have tax consequences.
Program Fees
The standard Program Fee is as follows:
Account Asset Value Annual Fee
Your Account Value 0.35%

The annual fee is billed quarterly in advance. The fee schedule is generally not negotiable, however we may from time to time
use special promotional rates and/or give a discounted rate based on Wells Fargo relationship or employment status with
Wells Fargo. A promotional rate or discounted rate is subject to end due to the end of the promotion or a change in
relationship or employment status. Advisory Programs typically assume a normal amount of trading activity and, therefore,
under particular circumstances, prolonged periods of inactivity may result in higher fees than if commissions were paid
separately for each transaction.
You should be aware that Program fees charged may be higher or lower than those otherwise available if you were to select a
separate brokerage service and negotiate commissions in the absence of the extra advisory service provided.
Calculating Account Values and Fees. Unless agreed to otherwise, we will deduct fees at the rate shown in the Fee
Schedule quarterly in advance. For the purposes of calculating the Program fees, "Account Value" means the sum of the
absolute market value of all Program Assets.
In valuing Accounts, we will utilize information provided by quotation services believed to be reliable. If any prices are
unavailable or believed to be unreliable, we will determine prices in good faith so as to reflect our understanding of fair market
value.
The Account Value for the calculation of fees may differ from that shown on your monthly Account statement and/or online
reports depending on several factors, including trade date or settlement date accounting and other factors.
Quarterly Fee. The initial fee is calculated as of the date that the Account is accepted into the Program and covers the
remainder of the calendar quarter. There may be a short delay between inception and initial transactions. Subsequent fees
will be determined for calendar quarter periods and shall be calculated on the basis of the market value of the Program
Assets held for your Account on the last business day of the prior calendar quarter.
If your Account does not have a sufficient cash balance to make a payment on the due date, we may sell Program Assets in
your Account, without prior notice to you, to generate proceeds sufficient to pay the Program Fee and any other fees and
charges payable.
The Program Fee is separate and distinct from the fees and expenses charged by the ETFs to their shareholders.
Consequently, the ETFs held in your Account are subject to internal fees and/or expenses, which may include advisory and/or
brokerage fees. WFA and its affiliates may earn or receive a portion of such fees and expenses in connection with the
advisory or brokerage services they provide as sponsor or distributor of an affiliated Program Fund.
Additions and Withdrawals. Your Account will be charged (or refunded) a prorated quarterly fee on any net additions (or net
withdrawals) in the Account during a month.
• Fees will be charged (or refunded) if the net addition or (net withdrawal) would generate a fee (or refund) of at least
$40 for that quarter.
• Fees will be assessed in the month following the net addition (or net withdrawal).
• Fees are based on the value of the assets in your Account as determined by the fee schedule. We are not
compensated on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of your
funds.
Other Account Fees
The Program fee does not include certain charges that may be applicable, including:

593718 (Rev 16 - 05/22) Page 6 of 23

 • Dealer markups or markdowns
• Odd lot differentials
• Transfer taxes
• Exchange fees or similar fees charged by third parties, including issuers, and fees required by the SEC
• Execution fees (foreign and/or domestic) when applicable
• Other fees required by law

Non-Brokerage-Related Fees. Non-brokerage related fees, such as IRA fees and wire transfer fees, are not included in the
Program fee and will be charged to your Account separately. Please consult the Annual and Operational Fee Schedule for a
list of these non-Program related fees and charges identified as applicable to advisory Accounts.

Prior Commissions or Charges. To the extent that cash used for investment in the Program comes from redemption
proceeds of or deposits of your existing mutual funds or other securities investments, you should consider the cost of any
prior sales charges or commissions you paid, which are in addition to the Program fee.

Selling Securities. If you sell securities prior to initiating (or after terminating) the Program, you will pay the separate
brokerage charges for those transactions, in addition to applicable Program fees during the period.

If you fund your Program Account with securities, they will be liquidated at no additional cost under the Program Fee.
However, if these securities include a mutual fund with a back-end sales charge, that charge will still be applicable.

Costs of Investing in Program Assets

ETFs. In addition to the Program Fee, as a shareholder of an ETF, you will bear a proportionate share of the fund's
expenses, including investment management fees that are paid to the fund's investment adviser, who may be an affiliate of
ours. For more information about these funds, see their prospectus.

You should be aware that you can invest in ETFs directly without incurring the fee charged for participation in the Program.

Cash Sweep Program. Accounts opened must provide consent, through the general account opening agreement, to use our
Cash Sweep Program. Through our Cash Sweep Program you may earn a rate of return on the uninvested cash balances in
your Account by automatically placing ("sweeping") cash balances into a sweep vehicle until such balances are invested or
otherwise needed to satisfy obligations arising in connection with your Account. The available cash sweep vehicles currently
consist of (1) interest-bearing deposit accounts at affiliated and unaffiliated banks in our Expanded Bank Deposit Sweep
program, (2) interest-bearing deposit accounts at two affiliated banks in our Standard Bank Deposit Sweep program (together
with the Expanded Bank Deposit Sweep Program, the "Bank Deposit Sweep Programs"), and (3) one or more affiliated and
non-affiliated stable-value Money Market Mutual Funds ("Money Market Sweep Funds"). Eligibility for each available sweep
vehicle is determined by account type. You may elect not to participate in the Cash Sweep Program and/or periodically invest
cash balances directly in available money market mutual funds or other products offered as direct investments outside of the
Cash Sweep Program by providing instructions to your investment professional. If you choose not to participate in the Cash
Sweep Program, except for retirement accounts, accruing cash balances will not earn a rate of return prior to direct
investment. In addition, available cash will not be automatically swept into any money market mutual fund or other investment
that you purchase outside of the Cash Sweep Program. The Cash Sweep Program is subject to the terms and conditions of
the Cash Sweep Program Disclosure Statement.

As returns on the Cash Sweep, your personal financial circumstances, and other factors change, it may be in your financial
interest to change your Cash Sweep (if another option is available for your account type) or invest cash balances in products
offered outside of the Cash Sweep Program consistent with your investment objectives and risk tolerance. Wells Fargo
Advisors does not have any duty to monitor the Cash Sweep for your account or make recommendations about, or changes
to, the Cash Sweep Program that might be beneficial to you.

Prior to receipt of the general account opening documents, cash deposited in the client's account and not otherwise invested,
will be held as a free credit balance and not placed in the Cash Sweep Program until written consent is provided to participate
in our Cash Sweep Program. While any cash remains in free credit balance, we will retain any interest earned on assets
awaiting investment or disbursement. You understand and agree that this interest (generally referred to as "float") will be
retained by us as additional compensation for the provision of services with respect to the account. Such interest shall
generally be a prevailing interest rate. Except for retirement accounts, while any cash remains in free credit balance, you will
not earn any interest on such balance.

Bank Deposit Sweep Programs

The Bank Deposit Sweep Programs consist of interest-bearing accounts at affiliated and unaffiliated banks in our Expanded
Bank Deposit Sweep program, and interest-bearing deposit accounts at two or more affiliated banks in our Standard Bank
Deposit Sweep program. Each unaffiliated and affiliated bank is a depository institution regulated by bank regulatory agencies
under various federal banking laws and regulations.

593718 (Rev 16 - 05/22) Page 7 of 23

We, along with our affiliates, including the affiliated banks, benefit financially from cash balances held in the Bank Deposit
Sweep Programs. As with other depository institutions, the profitability of the banks in the Bank Deposit Sweep Programs,
including affiliated banks, is determined in large part by the difference or "spread" between the interest they pay on deposit
accounts, such as Bank Deposit Sweep Programs, and the interest or other income they earn on loans, investments, and
other assets. The banks in the Bank Deposit Sweep Programs may pay rates of interest on the Bank Deposit Sweep
Programs that are lower than prevailing market interest rates. The participation of the affiliated banks in the Bank Deposit
Sweep Programs is expected to increase their respective deposits and, accordingly, overall profits.
With respect to the unaffiliated banks under the Expanded Bank Deposit Sweep Program, the financial benefits
available to Wells Fargo Advisors may differ as between retirement accounts and non-retirement accounts. For
retirement accounts (including IRAs), each unaffiliated Program Bank in the Expanded Bank Deposit Sweep program
will pay Wells Fargo Advisors a uniform fee equal to 79% of the Federal Funds Effective Rate of the average daily total
retirement account deposit balances at that unaffiliated Program Bank. Because each unaffiliated Program Bank will pay
us the same amount on retirement accounts, we have no incentive to make deposits with any particular unaffiliated
Program Bank. In the case of non-retirement accounts, each affiliated and unaffiliated Program Bank in the Expanded
Bank Deposit Sweep Program will pay Wells Fargo Advisors an amount not to exceed a percentage (equivalent to
Federal Funds Target plus 30 basis points (0.30%)) of the daily total non-retirement deposit balances at that Program
Bank, however the amount of that fee may vary from one Program Bank to the next. This amount includes our fee and
interest payable to participating accounts in the Expanded Bank Deposit Sweep.
In the Standard Bank Deposit Sweep Wells Fargo Advisors will receive compensation from the Affiliated Banks in an amount
not to exceed a percentage (equivalent to Federal Funds Target plus 30 basis points (0.30%)) of the daily total deposit
balances at the Affiliated Banks. The management personnel and other employees of Wells Fargo Advisors and its affiliates
receive incentive compensation based in part on assets in Affiliated Banks or the profitability of Affiliated Banks in the Bank
Deposit Sweep Programs and their joint parent company, Wells Fargo & Company.
Under the Expanded Bank Deposit Sweep, we pay an unaffiliated third-party administrator a fee for its services. This fee
includes an asset-based fee, which will vary based on deposit balances at the unaffiliated Program Banks. We do not pay the
third-party administrator on deposits held in the Affiliated Banks. Thus, the profitability of the Expanded Bank Deposit Sweep
is based in part on deposit balances, which may be greater depending on the size of the overall deposit balances in the
Expanded Bank Deposit Sweep.
Wells Fargo Advisors has a conflict of interest because it influences both what you receive in interest and what it and its
employees receive in compensation on the Standard Bank Deposit Sweep. This compensation is subject to change and we
may waive all or any part of this fee at any time without notice. As a result of the fees and benefits described above, the
Standard Bank Deposit Sweep will be more profitable to us than the Expanded Bank Deposit Sweep, which means we will
receive a greater benefit if you select the Standard Bank Deposit Sweep as your Cash Sweep.
Money Market Sweep Funds
Wells Fargo Advisors and its affiliates may receive distribution (Rule 12b-1), investment management, service fees and other
compensation as a result of sweeping available cash into the Money Market Funds. These fees, which vary depending on the
Money Market Fund (and class thereof) used, are paid directly by the Money Market Funds but ultimately borne by you as a
shareholder in the fund. Mutual fund companies typically offer multiple share classes with different levels of fees and
expenses. When selecting the share class for the Money Market Fund used as a Cash Sweep Vehicle, we do not, in all
instances, select the share class with the lowest fees that is available from the fund company and these decisions are
influenced by the additional compensation we receive in connection with your account's Money Market Fund holdings. The
use of a more expensive share class of a Money Market Fund as a Cash Sweep Vehicle will negatively impact your overall
investment returns.
The Cash Sweep Program should not be viewed as a long-term investment option. It is your responsibility to monitor your
balances in the Cash Sweep Program, and determine whether you prefer to invest cash balances in products offered outside
the Cash Sweep Program. For additional information, see the Cash Sweep Program Disclosure Statement, which we
provided to you when you opened your Account. For additional information about the Cash Sweep Program, including
information about how we and our affiliates benefit from the Cash Sweep Program, see the Cash Sweep Program Disclosure
Statement, which we provided to you when you opened your Account.
Compensation
Compensation from Investment Advisors. We receive training and education payments from many of the companies
whose ETFs we sell for conducting comprehensive training and education for Associates. Wells Fargo Advisors may receive
different training and education payments from ETF product sponsors depending on the training and education activities
provided. From time to time, ETF product sponsors will reimburse us for expenses in connection with conducting training and
educational meetings, conferences or seminars for Associates and customers. Also, Associates may receive promotional
items, meals or entertainment or other "noncash" compensation from product sponsors. Although training and education
compensation is not related to individual transactions or assets held in Client Accounts, it is important to understand that, due
to the total number of companies whose products are offered by us, it is not possible for all the product sponsors affiliated
with each company to participate in a single meeting or event. Consequently, those product sponsors who participate in
training, an educational meeting, seminar or other event gain an opportunity to build relationships with Associates that could
lead to additional sales of the sponsor's ETF products. ETF sponsor policies can be found in an ETF's prospectus, which is

593718 (Rev 16 - 05/22) Page 8 of 23

available on request from the ETF product sponsor. While we offer a wide variety of ETFs for our Associates to sell or
recommend, we reserve the right in the future to limit branch access to ETF sponsors.
Our affiliates may receive compensation for making a market and keeping an inventory of select ETF offers. They may also
have an investment banking relationship with ETF issuers.
Licensing Fees. Certain ETF sponsors pay our affiliates a licensing fee to create ETFs that track a Wells Fargo index. That
fee is based on the assets under management of the ETF. For purposes of calculating the index licensing fee, WFA
discretionary ERISA and IRA assets invested in an ETF based on a Wells Fargo index are excluded from the calculation.
Differing Compensation. The additional compensation received from ETF sponsors may vary. As a result, the
compensation may offer us a financial incentive to recommend one ETF over similar ETFs. This could also result in an
increase in your cost as a result of us recommending a more expensive ETF. We intend, however to make all
recommendations independent of such financial considerations and based solely on our obligations to consider your
objectives and needs.
We do not pre-condition the recommendation of ETFs for inclusion in the Program based on any compensation we may
receive. In addition, Wells Fargo is a full-service financial services firm with many affiliates. Wells Fargo encourages its
subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual
business planning, business with our affiliates is included in establishing our sales goals. As a result, we may have an
incentive to hire affiliate service providers for our advisory Programs. We intend, however, to make all recommendations
independent of any such goals and based solely on our obligations to consider your objectives and needs.
Account Termination
You or we may terminate an Advisory Program Account by notifying the other party in writing of the Advisory Program
Account to be terminated and termination will become effective upon the receipt of the notice. If an Advisory Program Account
is terminated, we will make a pro-rata refund to you of fees paid to us pursuant to the Agreement for the period after the date
of effectiveness of such termination through the end of the then current fee period. Termination of the Account will not affect
either your or our responsibilities under this agreement for previously initiated transactions or for balances due in the Program
Account upon termination.
If for any reason you are not satisfied with the Program, you are entitled within 90 days of Account opening to terminate your
Program Account and be credited for any portion of the Program Fee that you have paid. Please note: this will not refund
market losses.
Upon termination, you may, but are not required to, request that we liquidate your Account.
• You should also keep in mind that the decision to liquidate Program Assets may result in tax consequences that
should be discussed with your tax advisor.
We are not responsible for market fluctuations in your Account from time of written notice until complete liquidation. Your
request to liquidate securities upon termination of this Agreement is not considered a market order, since both we and/or the
Manager require time to process your request. All efforts will be made to process the liquidation in an efficient and timely
manner. It may take several business days under normal market conditions to process your request. Should the necessary
securities markets be unavailable and trading suspended, efforts to trade will be done as soon as possible following their
reopening.
Upon Termination, your Program Account will become a brokerage Account. If securities remain in the brokerage Account
after termination, neither the Manager nor WFA and our affiliates will provide any investment recommendations or ongoing
investment management, nor will we give advice or offer any opinion with respect to the suitability, profitability, or
appropriateness for you of any security, investment, financial product, or investment strategy. You will be solely responsible
for determining whether a security transaction or strategy is suitable for you. All transactions will be done only on your order
or the order of your authorized delegate, except as otherwise provided in the Program Agreement. Further, upon the
termination of your Program Account, your assets will be subject to all fees and charges normally assessed by WFA and/or its
agents on its standard brokerage Accounts.

Account Requirements and Types of Clients

Account Requirements
A minimum initial Account value of at least $500 is required. Under certain circumstances the Account minimum may be
waived. We may terminate your Account with notice if they fall below minimum Account value guidelines established by us.
To participate in the Program, you must establish a Program Account and enroll in the Program electronically through the
Program Website.
Types of Clients
We provide the advisory services described in this brochure generally to individuals, through taxable or retirement Accounts,
and trusts.

593718 (Rev 16 - 05/22) Page 9 of 23

Portfolio Manager Selection and Evaluation
Our affiliate, WFII, has created nine Globally Diversified ETF portfolios and nine Sustainability Focused ETF portfolios that
are available within the Program. These Portfolios are built based on specified investment objectives, risk/return profiles and/
or targeted asset allocations.
For all available portfolios, the allocation targets are generally based on longer-term risk/return assumptions for various
asset classes or investment strategies and may change from time to time in light of new research and analysis. The asset
allocation guidelines and risk/return objectives are selected such that the Conservative Income model would be expected
to generally have the lowest long-term investment risk, based on historical average risk levels, but also the lowest
expected return. As an investor moves to models with higher allocations in equities or other higher-risk assets, historical
averages suggest that expected investment risk and potential return increase. A description of the Portfolios can be found
in the "Methods of Analysis, Investment Strategies and Risk of Loss" section.
WFII uses both quantitative and qualitative criteria when evaluating the potential inclusion, combinations and weights of ETFs
in a Portfolio. WFII will typically arrange meetings with Portfolio Managers or representatives of an ETF sponsor to discuss
the underlying investment philosophy of the fund manager and how that philosophy is manifested in security buy, sell and
weighting decisions. They also seek to understand the capabilities of the Portfolio Manager, and assess how the investment
philosophy will perform in different market environments. Additional factors influencing the inclusion and weight of an ETF
within a portfolio may include a statistical analysis of the fund's past risk/return profile; complementary nature; expense ratios;
assessed capacity and liquidity levels; tracking error versus specified indexes; the assessed quality of the investment
process; changes in investment process or personnel; the number, continuity and experience of the investment professionals;
a completed questionnaire, database information on the firm and interviews with members of the management team. This
process is a continuing one, and ETFs may be added or removed from the Program based on these ongoing assessments.
You are aware that ETF replacements in a Portfolio may cause tax consequences.
WFA and WFII use information, financial data, and investment research from a variety of sources to evaluate ETFs. We
believe the information we collect on funds is reliable and accurate, but we do not necessarily independently review or verify it
on all occasions.

The stated investment objectives and/or allocation guidelines for the Portfolios provide the general basis by which they will be
managed. We modify the allocations and/or selected ETFs when we believe it is in the interests of our investors to do so.

Other than in connection with our consulting responsibilities, we do not assume responsibility for the ETFs that we select,
including their performance or compliance with laws or regulations. You are advised and should understand that:
• An ETF's past performance is no guarantee of future results;
• There is a certain market and/or interest rate risk which may adversely affect any ETF's objectives and strategies,
and could cause a loss in your Account; and
• Client risk parameters or comparative index selections provided to us are guidelines only; there is no guarantee
that they will be met or exceeded.

You should also be aware that shares of any particular ETF may fluctuate in value and when sold may be worth less than
their original cost. There is no guarantee that your Program Portfolio will protect against such loss of investment.

Our reasons for removing an ETF may include its failure to adhere to expected investment objectives or a given management
approach, a material change in the professional staff managing the fund, unexplained poor performance, a change of the
investment management process, or the identification of a better alternative. We will, at our sole discretion, determine
whether any or all of these factors are material when deciding to make a replacement.

WFII meets as necessary to make appropriate changes to the current asset allocation recommendations. We will review
these recommendations and apply them to the Portfolios, as appropriate.

We may give advice and take action in the performance of our duties to you that differ from advice given, or the timing and
nature of action taken, with respect to other Program Clients and/or Clients in other advisory Programs. Additionally, we, from
time to time, may not be free to divulge or act upon certain information in our possession on behalf of investment banking or
other confidential sources.

Services Tailored to Individual Client Needs

All of our investment recommendations for Program Accounts are based on an analysis of your individual financial needs.
They are drawn from research and analysis we believe to be reliable and appropriate to your financial circumstances. Each of
the advisory services we offer is tailored to a specific type of investor and designed to meet their individual investment
objectives, financial needs and tolerance of risk. A detailed description of these Programs is provided in the "Services, Fees
and Compensation" section.

593718 (Rev 16 - 05/22) Page 10 of 23

Client Restrictions and Instructions

We will comply with any reasonable instructions and/or restrictions you give us when making recommendations for your
Account, including the designation of securities that should not be purchased or held in the Account.
• If we believe that the restrictions are unreasonable or inappropriate, we will notify you that, unless they are
modified, we may remove your Account from the Program.
• You will not be able to provide restrictions that prohibit or restrict the purchase or sale of securities by the
investment advisor of an ETF.
• If you wish to restrict more than one of the ETFs in a particular asset class, we may remove your Account from the
Program.

Our policy is generally to liquidate your existing securities portfolio immediately in newly established Program Accounts and
reinvest the Account in conformity with your target allocations. If you wish to hold certain positions for tax or investment
purposes, you should consider holding these positions in a separate Account.

Performance-Based Fees and Side-By-Side Management

We do not charge performance-based fees in any of our investment advisory Programs. We do not have any side-by-side
management situations.

Methods of Analysis, Investment Strategies and Risk of Loss

The Intuitive Investor Program offers the Globally Diversified portfolios and Sustainability Focused portfolios as described
below. Each portfolio series offers nine investment objective-based portfolios.

Globally Diversified portfolios

Globally Diversified portfolios combine traditional market-capitalization-weighted ETFs intended to provide low-cost core
portfolio exposures with complementary smart beta or enhanced-index ETFs within select asset classes to increase
exposures to factors/characteristics that can potentially enhance longer-term risk and return outcomes. The factors used by
smart beta ETFs for screening and weighting purposes are often related to relative measures of quality, volatility, valuation,
momentum, and other metrics focused on enhancing overall diversification. The individual and combined factor-related
metrics and screening employed by smart beta ETFs can be similar to select screening employed by active managers in an
attempt to add value over a traditional market-cap-weighed passive approach. However, because the screening/weighting
approaches employed by smart beta ETFs are systematic in nature and designed to replicate broad market factor-tilted
indices, their relative expenses remain low in comparison to actively managed alternatives. In combination, the portfolios
selected ETFs and weightings are intended to provide a relatively low-cost approach, but with the potential for enhanced
outcomes (compared to employing only a traditional market-weighted passive approach) while maintaining the relative cost
efficiencies and other potential benefits of an all-ETF portfolio. Though the intention is to enhance potential longer-term
outcomes relative to more traditional size-weighted passive approaches, it should be recognized that the differences in
weighting methodologies can result in periods of both significant outperformance and underperformance for particular or
combined smart beta ETFs versus corresponding broad market indices.

Sustainability Focused portfolios

Intuitive Investor Sustainably Focused portfolios focus on the use of ETFs that through specific index replication or systematic
screening of broad market indices seek to accentuate exposures to companies with relatively strong Environmental, Social,
and Corporate Governance ("ESG") practices/ratings while deemphasizing or avoiding companies with low ESG ratings and
related potential controversies. The combined accentuation of these considerations is intended to increase focus on practices
that can help promote a more sustainable environment and more sustainable, ethical, and community-minded businesses.
The ETFs often use both inclusionary and exclusionary criteria to both increase and reduce/eliminate exposures based on
relative ESG practices/metrics and specific areas of business involvement. However, the overall approach is generally more
relative in nature with greater focus on favoring companies with relatively favorable ESG practices/metrics by industry and
thereby still maintaining broad industry and economic sector exposures. While this approach to investing is intended help
drive more positive and less detrimental environmental and social impact, from a purely investing point of view integrating an
ESG lens is also intended to serve as an additional component of risk management. The lens can help to further identify
potential relative risk exposures for specific companies that could result in potential significant business and reputational risks
and impairment. While over longer periods of time performance for ESG-oriented investing is generally expected to be in line
with that of the broad market, given some of the inherent factor and sector biases there can be periods over the course of
economic/market cycles when such strategies can substantially underperform or outperform their respective broader market
indices.

Below are descriptions of the nine investment objective-based portfolios in each portfolio series that are available in the
Program.

593718 (Rev 16 - 05/22) Page 11 of 23

Income: Portfolios emphasize current income with minimal consideration for capital appreciation and usually have less
exposure to more volatile growth assets.
• Conservative Income: Conservative Income investors generally assume lower risk, but may still experience
losses or have lower expected income returns.
• Moderate Income: Moderate Income investors are willing to accept a modest level of risk that may result in
increased losses in exchange for the potential to receive modest income returns.
• Aggressive Income: Aggressive Income investors seek a higher level of returns and are willing to accept a higher
level of risk that may result in greater losses.

Growth & Income: Portfolios emphasize a blend of current income and capital appreciation and usually have some exposure
to more volatile growth assets.
• Conservative Growth & Income: Conservative Growth and Income investors generally assume a lower amount of
risk, but may still experience losses or have lower expected returns.
• Moderate Growth & Income: Moderate Growth and Income investors are willing to accept a modest level of risk
that may result in increased losses in exchange for the potential to receive modest returns.
• Aggressive Growth & Income: Aggressive Growth and Income investors seek a higher level of returns and are
willing to accept a higher level of risk that may result in greater losses.

Growth: Portfolios emphasize capital appreciation with minimal consideration for current income and usually have significant
exposure to more volatile growth assets.
• Conservative Growth: Conservative Growth investors generally assume a lower amount of risk, but may still
experience increased losses or have lower expected growth returns.
• Moderate Growth: Moderate Growth investors are willing to accept a modest level of risk that may result in
significant losses in exchange for the potential to receive higher returns.
• Aggressive Growth: Aggressive Growth investors seek a higher level of returns and are willing to accept a high
level of risk that may result in more significant losses.

Risks Associated with Sustainability Focused Investing

The performance of the strategies that include the evaluation of a company’s performance related to identified ESG goals in
the investment process may be lower than other strategies that do not include a company’s performance and ESG goals in
the investment evaluation process. WFII seeks to identify ETFs that it believes can offer attractive investment returns while
also aligning with their specific ESG goal of its Clients, but may not be successful in achieving both. Successful application of
the ESG performance analysis will depend on WFII’s ability to identify and analyze a company’s ESG performance data and
information, and there can be no assurance that the strategy or techniques employed will be successful or that available
information is adequate or accurate. Further, investors may differ in their views of what constitutes positive or negative ESG
outcomes. As a result, a WFII strategy may invest in companies that do not reflect the beliefs and values of a particular
investor. WFII does not provide recommendations or takes action to vote proxies, or participate in class actions, for assets in
Intuitive Investor strategies.

The ETFs selected within the ESG space, and used within the Sustainability Focused portfolios, may use exclusionary criteria
based on percentage of revenue derived from specified areas of business involvement. The exclusions are generally related
to environmental impact or controversial products or business practices. Apart from these specific exclusions, the ETFs may
use systematic means to increase weights/exposure to companies with more favorable ESG metrics/practices based on index
provider and/or third-party ESG research, and reduce exposure to companies with less favorable ESG metrics/practices,
while seeking to maintain overall performance within a specified threshold of the referenced broad market index. The
combined process seeks to consider/emphasize ESG-related factors while also maintaining overall sufficient portfolio
diversification. Examples of Environmental third-party research focus include: climate risks, biodiversity impact, fossil fuel
extraction/use, waste production and management, and renewable energy. Areas of Social focus include: labor standards and
practices, diversity and inclusion, product liability, consumer protection and data security, and philanthropic giving and
community involvement. With respect to Governance, the focus is generally on board structures, accounting standards and
practices, regulatory and compliance records, and current/potential controversies. While these areas of focus differ from more
traditional investment research focused on specific company financials and operating fundamentals, many ESG factors can
have material financial impact based on both potential business risks and opportunity.

In addition to its standard research and product selection process, WFII’s ESG-related research focuses on the ongoing
screening and systematic weighting processes used by ETF and index providers to integrate ESG factors. WFII’s research
and relative assessments are applied on an ongoing basis.

Program Website Tool Methodology

The suggested asset allocation strategy generated by the Program Website Tool ("Tool") is based on your answers to the
questionnaire, which is comprised of a series of questions regarding, among others, your investment objective, risk tolerance,

593718 (Rev 16 - 05/22) Page 12 of 23

investment time frame, and liquidity. The Tool selects the suggested asset allocation strategy from one of 9 possible
investment objectives. After a recommended investment objective is provided, you will then have the option to move forward
with that recommendation or select an investment objective that is one step lower or one step higher on our risk scale. In
addition, once an investment objective is selected, you will then have the option to select a portfolio from either our Globally
Diversified series or from our Sustainability Focused series.

The asset allocation strategies for each of the 9 investment objectives are based on Wells Fargo Investment Institute's
(WFII's) Capital Market Assumptions ("CMAs"). The CMAs are estimates of the expected 10- to 15-year risk and return for
each asset class within the prescribed allocations. They reflect the trends that WFII believes are most likely to affect
investments in the coming years given the assessment of key economic and market drivers, appropriate historical context,
and trends that we expect to develop over time. The assumptions are reviewed annually by WFII and are subject to change
as conditions vary. Such assumptions are not a prediction or guarantee of returns or performance that may be realized and
are subject to inherent limitations.

The suggested asset allocation strategies are proprietary to Wells Fargo and intended to be implemented only in conjunction
with an Intuitive Investor Account. You are the one to decide whether to act on the suggested asset allocation strategy by
opening and funding an Intuitive Investor Account.

Tool Updates and Responsibility for Information Provided. We will periodically update the Tool, which could include
changes to the questions and modifications to the scoring methodology that generates the recommended asset allocation
strategy. Your asset allocation strategy will not update automatically when we update the Tool. Results generated by the Tool
after an update may be different, even if your answers are the same or similar to what you provided previously. Your updated
results should be considered in place of any previous results. The results provided by the Tool depend upon the accuracy of
the information you provide. Wells Fargo is not responsible for the accuracy or appropriateness of the information you
provide.

Limitations on the Use of the Tool. The Tool's analysis does not consider the effects of taxes, fees, and/or expenses
associated with investing. The Tool should not be considered as legal or tax advice. Please consult a tax professional to
review the suggested asset allocation strategy, its fees, and tax consequences prior to making an investment decision.

Risk Considerations and Disclosures. You are under no obligation to accept the asset allocation strategy suggested by
the Tool. You should carefully consider all of your options, as well as your other assets and investments before opening an
Intuitive Investor Account and investing in the suggested asset allocation strategy. As your financial circumstances or goals
change, consider revisiting the Tool. Wells Fargo is not responsible for reviewing your financial situation, and the Tool's
investment advice should not be considered comprehensive in regards to your financial situation.

There is no guarantee that any particular asset allocation strategy and its underlying funds, paired with an Intuitive Investor
Account, will ensure your ability to meet any of your investment goals or provide you with income. Asset allocation strategies
and diversification do not guarantee a profit or protect against loss. All investing involves risk including the possible loss of
principal. An investment in a fund will fluctuate, and shares, when sold, may be worth more or less than their original cost.

Risk of Loss. All investments shall be at your risk exclusively and we do not guarantee any return on the investments
recommended or advised upon. We will not be responsible for losses resulting from the management of your Account. The
Program includes investment risks, including possible loss of principal.

Proxy and Reorganizations

You delegate proxy voting authority to a third party proxy voting service provider, currently Institutional Shareholder Services
Inc. (“ISS”), which we have engaged to vote proxies on your behalf to act (or refrain from acting) with respect to proxy
information related to securities, or the issuer of securities, held or formerly held in an Account. ISS will vote proxies on your
behalf in accordance with its established guidelines. ISS' services do not apply to proxies they decline to vote. When using
ISS' services, you will not receive proxy materials or annual reports related to securities or other property. In the case where
ISS declines to vote, you will not receive proxy materials and the proxy will not be voted.

For any corporate proposal [for investment companies registered under the Investment Company Act of 1940, including
mutual funds, closed-end funds, ETFs and UITs] which does not require a proxy (e.g., tender offers or repurchase offers),
neither we nor your advisor will exercise discretion in choosing an option on the proposal. Instead of exercising discretion, we
will refrain from acting and these positions will be treated as unvoted. As an example, in the case of a repurchase offer by a
fund, your shares will not be offered for repurchase by the fund.

You have the ability to rescind this proxy voting authorization by providing written instruction to us appointing either yourself or
a third party authorized to act on your behalf. You may not delegate proxy voting authority or authority to exercise discretion
on reorganization proposals to us and we will not be obligated to render any advice or take any action with respect to
information related to securities, or the issuer of such securities held in the Account. Information regarding ISS' services and
its U.S. Proxy Voting Guidelines are available via ISS' website https://www.issgovernance.com/policygateway/voting-policies.
We may change the third party proxy voting service provider and will not be deemed to have or to exercise proxy voting
responsibility or authority by virtue of such action.

593718 (Rev 16 - 05/22) Page 13 of 23

Client Information Provided to Portfolio Managers
When completing the Risk Tolerance Questionnaire, we will ask you to provide information about your investment objectives,
financial circumstances and risk tolerance. Based on this information, we will make a recommendation using research and
analysis we reasonably deem to be reliable. We may share this information with the Manager.
• We will contact you at least annually to update your information and indicate if there have been any changes in
your financial situation, investment objectives or restrictions.
• It is your responsibility to inform us of any material change in your financial circumstances that might affect the
manner in which your assets should be invested. Failure to do so could affect the suitability of the services that we
are providing to you.

We will act on any changes deemed to be material or appropriate as soon as practical after we become aware of the change.

Client Contact with Portfolio Managers

We will make our investment advisory and support personnel reasonably available for consultation with you if you request.
You can request assistance by phone at (855) 283-5567.

Additional Information
Disciplinary Information

We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of
the broker-dealer, investment advisor, or predecessor firms.

For more information on broker-dealer related disciplinary events you may visit:
http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/.
Our investment advisory disciplinary history is available by going to: http://www.adviserinfo.sec.gov/ .
• In December 2021, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed
to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the
Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti-money laundering
Customer Identification Program (CIP) in the required non-erasable and non-writable “Write Once, Read
Many” (WORM) format in violation of Exchange Act Rule 17A-4(F)(2)(II)(A) and failed to notify FINRA prior to using
the non-WORM compliant storage platform in violation of Exchange Act rules 17A-4(F)(3)(V) and 17A-4(F)(2)(I).
Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine,
jointly and severally, of $2,250,000.
• On August 27, 2020, Wells Fargo Clearing Services, LLC agreed to a settlement with FINRA regarding allegations
that the Firm failed to reasonably supervise the activities of two former registered representatives, thus violating its
own written supervisory procedures along with NASD Rule 3010(a) and FINRA Rules 3110(a) and 2010. Between
November 2012 and October 2015, the two representatives recommended that many of their customers invest a
substantial portion of their assets in four high-risk energy securities, which generated multiple red flags regarding
over concentration and suitability in their customers' accounts that the firm failed to reasonably investigate. The
Firm has previously compensated 67 clients over $9.7 million for losses in these investments. Without admitting or
denying the findings, the Firm agreed to a settlement that included a censure, a fine of $350,000 and restitution in
the amount of $201,498 plus interest to additional specified clients.
• On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against Wells
Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, following the Firms' offers of
settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that
many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded
funds ("ETFs") without having adequate compliance policies and procedures and without providing financial
advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain
investment adviser representatives and registered representatives made unsuitable recommendations to certain
clients. The Commission found that the Firms willfully violated Section 206(4) of the Advisers Act and Rule
206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section
203(e)(6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of
Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained
in the Order, to: (a) cease and desist from committing or causing any violations and any future violations of Section
206(4) of the Advisers Act and Rule 206(4)-7 thereunder, (b) be censured, and (c) jointly and severally pay a civil
monetary penalty in the amount of $35,000,000.

593718 (Rev 16 - 05/22) Page 14 of 23

 • In 2018, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC elected to
participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative
("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report
to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures
concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment
Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to
mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms
jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of
the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease
and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling
$17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms
self-reported.
• In December 2017, Wells Fargo Advisors agreed to a settlement with the State of Illinois Securities Department
regarding allegations that it received, reviewed and/or analyzed documents and information from a financial
advisory firm concerning certain money manager strategies that contained information that was later found to be
false and misleading. The findings stated that we included the financial advisory firm's money manager strategies in
certain of our externally managed Separately Managed Account Programs, but that we did not utilize inaccurate
historical performance data in connection with our decision to on board the money manager strategies and we did
not incorporate inaccurate performance data in our advertisements or Program marketing materials. Without
admitting or denying the findings, the Firm agreed to a total monetary payment of $270,000.
• On December 21, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC
agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million
electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration
or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5
million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions
related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify
FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also
found that the Firms failed to implement an audit system for those records, failed to provide its third party vendors
full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce
written procedures. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and
severally, of $1,500,000. The Firms also consented to a review of its policies and procedures.
• On December 5, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC
agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce
reasonable supervisory systems for the use of consolidated reports generated by their registered representatives
through available applications. The findings stated that these applications allowed the Firm's representatives to
manually enter information regarding customers' external accounts, assets and liabilities into a centralized table
which the Firms maintained. This information would then be used to populate reports, including those that would be
sent to the Firms' customers. FINRA found that the Firms did not have systems in place to review the contents of
the reports, including information about customer holdings away from the Firms. In addition, the Firms supervisory
systems and procedures were inadequate because there was no mechanism allowing representatives to designate
which reports were actually provided to customers and the system could not distinguish between draft reports and
completed reports that were sent to customers, which should have been subject to the Firms' supervisory systems
designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a
censure and fine, jointly and severally, of $1,000,000.
• In December 2014, Wells Fargo Advisors agreed to a settlement with FINRA regarding allegations that the Firm
failed to comply fully with requirements to verify the identity of each customer opening a new account under its
Customer Identification Program ("CIP"). Due to a design flaw in the Firm's CIP system, 220,000 accounts, out of
the total 6.9 million accounts opened during the period from October 2003 through October 2012, were not subject
to the Firm's CIP review. When considering sanctions, FINRA took into consideration that WFA discovered the
system flaw through self-testing, performed remediation CIP on approximately 100,000 accounts that remained
open, made system changes to prevent recurrences and reported the violations in accordance with FINRA Rule
4530(b). Without admitting or denying the allegations, the Firm agreed to a settlement that included a censure, and
payment, jointly and severally with its affiliate Wells Fargo Advisors Financial Network, of a $1,500,000 fine.

593718 (Rev 16 - 05/22) Page 15 of 23

 • On September 22, 2014, the Securities and Exchange Commission ("Commission") entered an order against Wells
Fargo Advisors, LLC following the firm's offer of settlement. The order stated that the firm did not adequately
establish, maintain or enforce policies and procedures to prevent the misuse of material nonpublic
information, particularly concerning the risk that its associated persons could obtain material nonpublic information
from its customers or advisory clients. The order also stated that during the Commission's investigation, the firm
unreasonably delayed production of certain documents and produced a document that was altered by an
employee. The firm admitted the Commission's findings of fact, acknowledged that its conduct violated the federal
securities laws and agreed to retain an independent compliance consultant to review relevant policies and
procedures, as well as the making, keeping, and preserving of certain required books and records. The order
censured the firm, required that the firm cease and desist from violating the federal securities laws cited in the order
and imposed a civil money penalty in the amount of $5,000,000.

Other Financial Industry Activities and Affiliations

We are a national securities firm providing investment and other financial services to individual, corporate and institutional
Clients. We are a registered broker-dealer and investment adviser.

WFCS is a member of all principal stock exchanges in the United States, including the New York Stock Exchange and
NASDAQ. WFCS is also a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor
Protection Corporation ("SIPC"). We may also route Client transactions through its affiliate, Wells Fargo Securities, LLC.

We are a non-bank affiliate of Wells Fargo. We are not a bank or thrift and are a separate and distinct corporate entity from
our affiliated banks. Unless otherwise stated as the case, the investment advisory services offered and the underlying
stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not
insured or otherwise protected by the Federal Deposit Insurance Corporation ("FDIC") or another government
agency. They are not obligations of any bank or any affiliate of us; are not endorsed or guaranteed by Wells Fargo,
WFA, or any bank or any affiliate of us; and involve investment risk including possible loss of principal. Cash
balances in your Accounts, if eligible, will be held in a depository Account at a Wells Fargo entity. Deposit Accounts,
like the bank deposit sweep, are protected by FDIC insurance up to applicable limits.

Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible
for securities we sell or purchase. As a general matter, unless otherwise stated, we may be a principal or engaged in
underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase
those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to
issuers whose securities may be sold to you.

From time to time, a bank or thrift affiliated with us may lend money to an issuer of securities underwritten or privately placed
by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will
disclose to the extent required by applicable securities laws:

• The existence of any material lending relationship by any affiliate of ours with such an issuer and
• Whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding
indebtedness to any of our affiliates.

We have a number of related persons who may provide investment management and related financial services to our
advisory Clients. The advisory services these investment advisers offer are described more fully in their Disclosure
Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services
follows.
• Wells Fargo Advisors Financial Network, LLC is an affiliate of WFA that also provides retail brokerage
and investment advisory services.
• Wells Fargo Investment Institute, Inc. (known prior to November 1, 2014 as Alternative Strategies Group, Inc.
and before that as Wachovia Alternatives Strategies, Inc.) is a registered investment advisor and wholly owned
subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA.

Wells Capital Management Incorporated, Wells Fargo Funds Management, LLC, Wells Fargo Asset Management
(International) LLC, Wells Fargo Funds Distributor, LLC and Galliard Capital Management, Inc. will no longer be related
persons of Wells Fargo Clearing Services, LLC (“WFCS”). These companies were wholly owned by Wells Fargo & Company
(“Wells Fargo”) and formed the asset management business that Wells Fargo operated under the trade name Wells Fargo
Asset Management. These companies served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of
the separately managed account programs offered through WFCS. Wells Fargo sold the Wells Fargo Asset Management
business in 2021 and the new owners subsequently renamed the business Allspring Global Investments. The sale closed on
November 1, 2021.

Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global
Investments Holdings, LLC. This group of companies includes Allspring Funds Management, LLC, the investment adviser to
each of the mutual funds within the Allspring Global family of funds, and Allspring Funds Distributor, LLC, the principal

593718 (Rev 16 - 05/22) Page 16 of 23

underwriter of the Allspring Global mutual funds. It also includes Allspring Global Investments, LLC, an investment adviser to
pooled investment vehicles and separately managed accounts.

Wells Fargo will have no role in the management of Allspring. However, Wells Fargo will retain less than a 10% equity
ownership interest in Allspring and, for a limited period of time following the close of the sale, continue to provide research
and certain non-advisory transition services to Allspring for a fee. WFCS will continue to receive compensation from Allspring
for the distribution, administrative and operational services that we provide to the Allspring Global mutual funds. Additionally,
WFCS and Wells Fargo Investment Institute, Inc. (“WFII”) will continue to provide Allspring, for a fee, with thematic
recommended lists and research regarding individual equities used by Allspring to construct portfolios for separately managed
accounts that are exclusively distributed by WFCS and its related persons. For a limited period of time, WFII will also continue
to provide manager research to Allspring for a fee.

Wells Fargo’s equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services
and research to Allspring for a fee will provide us with a financial incentive to continue to recommend to our clients products
that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account
programs. Although Allspring will not be a related person of WFCS, WFCS and its related persons will continue to benefit
from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a
similar financial interest.

Access to Research. WFII also provides research and strategy recommendations to other affiliates of WFA and within other
Programs offered. While all the affiliates have similar access to the research, due to the operation differences, manner and
size of the advisory programs, certain affiliates may be able to implement and trade on these recommendations prior to
another affiliate. The ability to implement and trade on these recommendations first, may give the clients of one affiliate an
advantage over clients of other affiliates.

Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Code of Ethics

Our Associates are subject to a Code of Ethics that is designed to ensure our business activities are performed with the
highest possible standards of ethics and business conduct, and to comply with all applicable laws, rules, and regulations that
govern our businesses. Key requirements of our Code of Ethics are summarized below.
• Conduct all aspects of Wells Fargo's business activities in an honest, ethical, and legal manner, and in accordance
with all applicable laws, rules, and regulations and our policies and procedures.
• Provide accurate and complete information in dealings with Clients and others, including disclosure of conflicts of
interest when they exist.
• Prepare and maintain accurate business records.
• Refrain from improper disclosure or misuse of confidential Client information and material, non-public
information. Wells Fargo protects the private, personal, and proprietary information of Clients and others.
• Avoid conflicts of interest in personal and business activities.
• Rules specific to personal trading.

Participation or Interest in Client Transactions

Under the Program, we are generally appointed as sole and exclusive broker by you for the execution of transactions. The
Program fee covers transaction costs when transactions are executed through us. However, on occasion, Clients may also
designate, or the law may require, the use of other brokers, taking into consideration a number of factors such as best
execution, research services, and other qualitative factors. Keep in mind that:
• When transactions are executed with other firms, including our affiliates, the cost of execution is imbedded in the
price of the security.
• Any imbedded execution costs on trades done away from us are in addition to the Program fee.

For these transactions, we may act as agent or, where permitted by law, principal (including when we are acting as
underwriter or selling group members). We may effect and execute brokerage transactions, including on a national exchange,
as permitted by current provisions of Section 11(a) of the Securities Exchange Act of 1934, as amended (the "Exchange Act")
and rules promulgated thereunder including any future amendments or changes to such statutes and rules. For more
information see the "Brokerage Practices" section.

Relationships with Publicly Traded Companies. We or our affiliates may have investment banking or other relationships
with certain publicly traded companies. These relationships may from time to time require us to restrict trading in the
securities of these companies. As a result of these investment banking or other activities, our affiliates may acquire
confidential or material non-public information that may prevent us or our affiliates, for a period of time, from purchasing,
selling or recommending particular securities for your Account. We and our affiliates are not permitted to divulge or to act
upon this information with respect to our advisory or brokerage activities.

593718 (Rev 16 - 05/22) Page 17 of 23

Additionally, we may be restricted or limited in our ability to purchase or sell particular securities or make investment
recommendations as a result of these affiliated activities.

Policies, Restrictions, and Training. We have certain restrictions, internal procedures, and client disclosures regarding
conflicts of interest that we may have with respect to our participation or interest in client transactions. We communicate our
policies and procedures related to participation in Client transactions to our Associates through compliance policies and
procedure manuals and program-specific policy guidelines.

Personal Trading

We have policies and procedures to mitigate conflicts of interest between your transactions and those in the personal
investment Accounts of our associates and their immediate family members. To ensure associate trading requirements are
observed:
• Certain associate trading activity is subject to pre-approval.
• All associates are subject to regular review by their supervisors and independent oversight by our Compliance
Department.
• Systemic controls are used to automatically restrict entry of certain orders and generate related surveillance
reporting.

Review of Accounts

Program services include review and monitoring of your Account by our personnel and facilities. Through the Website, we will
provide you with Account information which will include a calculation of your Account's performance.

Confirmations and Statements. We will provide you with the following:

• Trade confirmations reflecting all transactions in securities
• A statement of Account activity at least quarterly

These documents will be delivered to you electronically.

Prospectus Delivery

The Manager is authorized to accept on your behalf delivery of prospectuses for funds registered under the Investment
Company Act of 1940 (including ETFs). If the Manager accepts delivery of prospectuses on your behalf, WFA and the
Manager will generally not deliver a prospectus directly to you unless you request one. You may obtain a prospectus at any
time by contacting the team of Financial Advisors that are available to service your Account. Notwithstanding the authorization
described in this paragraph and apart from any requests you may make for a prospectus, WFA or the Manager may, in its
sole discretion, choose to deliver prospectuses directly to you.

Client Referrals and Other Compensation

From time to time, we initiate incentive programs for our Associates that may compensate them for:
• Attracting new assets and Clients
• Referring business to our affiliates (such as referrals for mortgages, trusts, or insurance services) or other
Associates
• Promoting investment advisory services
• Promoting green initiatives (such as raising Client awareness of paperless options)
• Meeting total production criteria
• Meeting length of service requirements
• Participating in advanced training
• Improving Client service

Associates who participate in these incentive programs may be rewarded with cash and/or non-cash compensation, such as
deferred compensation, bonuses, training symposiums, and recognition trips.

Because portions of these programs may be subsidized by external vendors or our affiliates, such as mutual fund companies,
insurance carriers, or investment advisers, associates have a financial incentive to recommend the programs and services
included in these incentive programs over other available products and services we offer.

Brokerage Practices

Under the Program, you will generally appoint us as sole and exclusive broker with respect to the referenced Account for the
execution of transactions which we may execute through our affiliate and from which such affiliate will derive benefits,
including benefits as a result of increased trading volumes. In connection with these transactions, we act as agent or, where
593718 (Rev 16 - 05/22) Page 18 of 23
permitted by law, principal (including instances wherein we or an affiliate are an underwriter or selling group member). You
authorize us to effect and execute brokerage transactions, including on a national exchange, as permitted by current
provisions of Section 11(a) of the Securities Exchange Act of 1934, as amended (the "Exchange Act") and rules promulgated
under the Exchange Act, including any future amendments or changes to such statutes and rules.

Principal Trades and Agency Cross-Transactions. We do not generally execute principal trades or agency cross-
transactions in our advisory Programs even though we may be permitted by agreement and by law to do so. Although in
some instances, we may be able to provide a more favorable market price to you if we participate in a principal trade or an
agency cross-transaction with Client Accounts, we do so only on a case by case basis, when consistent with regulations and
our obligations to provide best execution. If the trade is a principal transaction, we will provide you with specific disclosures
(including whether we are a market maker in the security) and obtain your consent.

Agency Cross-Transactions. If the transaction is an agency cross-transaction, in which we act as your broker or agent by
purchasing or selling securities from or to one of our brokerage Clients, we will obtain your written consent and will provide
you with a written confirmation at or before the completion of the transaction which describes its nature, provides information
about its date and time and the remuneration which may be received by the investment advisor or other person.

At least annually, we will provide you with a written disclosure statement identifying the total number of agency cross-
transactions for your Account during the period, and the total amount of our commissions or other compensation for these
transactions, if any. We generally will not affect agency cross-transactions between Clients if we have recommended the
security to both Clients.

Principal trades and agency cross-transactions are also subject to additional restrictions, procedures, and controls that are
not required for other securities transactions in advisory Accounts. As discussed more fully below, we seek to obtain the best
execution for each of our advisory Clients.

Cross-Transactions. We also may affect cross-transactions between advisory Client Accounts, where one Client purchases
a security held by another Client. Neither we nor any related party receives any compensation in connection with a cross-
transaction. We effect these transactions only when we deem the transaction to be in the best interests of both Clients and at
prices that we have determined to reflect fair value.

Fractional Shares. In addition to purchasing whole ETF shares for your Advisory Account, we will facilitate purchases and
sales of fractional ETF shares on your behalf, where doing so is required to ensure that the Advisory Account is allocated in
accordance with the selected Portfolio. WFA will facilitate purchases and sales of fractional shares for Client Accounts on an
agency basis by allocating excess fractional shares to a trade along account maintained by WFA. The trade along account
will enable WFA to aggregate client orders to purchase or sell fractional shares such that they may be placed in the market as
transactions in whole shares. WFA reserves the right to limit or stop facilitating transactions in fractional shares or to change
its policies and procedures that pertain to transactions in fractional shares, including but not limited to its allocation and
rounding procedures, at any time without prior notice to its clients. Fractional shares are typically unrecognized and illiquid
outside of the Advisory Account. As a result, fractional shares are not transferrable to another account. In the event you
request a transfer or liquidation of the assets in your Advisory Account, we will convert the fractional shares held in the
Account to cash. However, if your Advisory Account is terminated pursuant to the terms of your Agreement, the fractional
shares held in your Advisory Account will continue to be held in the standard brokerage account to which it reverts. Dividends
will be allocated pro-rata based on the fractional shares held in your Advisory Account.

Trade Corrections. If WFA is responsible for a trade processing error, it is WFA's policy to correct the issue as soon as
possible and return the Account to the economic position that it would be in absent the error. If correction processing
generates a shortfall to the Account, we make the Account whole by paying the shortfall. If correction processing generates
an overage (i.e., an amount in excess of what would be in the Account if the error did not occur), WFA retains the overage.

Rollovers. If you are rolling over assets from an employer-sponsored Qualified Retirement Plan ("QRP"), such as a 401(k),
to an Individual Retirement Account ("IRA") with us, you should carefully evaluate all choices which are typically available.
These four options include: leaving your assets in your former employer's plan (if permitted), rolling over the assets to your
new employer's plan (if permitted), rolling your assets to an IRA with us or another firm, or cashing out the Account value. You
should consider the following factors, among others, in deciding whether to keep assets in a QRP, roll over to an IRA or cash
out: investment options, fees and expenses, ability to make penalty-free withdrawals and differences in creditor protection.
We have a conflict of interest in connection with a rollover of your assets into an IRA and the investment of the assets with us
as opposed to leaving the assets in your former employer's plan or electing one of the other options. The conflict arises
because we will likely earn no compensation if you were to leave the assets in your former employer's plan or transfer to your
new employer's plan. In addition, the costs of maintaining and investing assets in an IRA with us will generally involve higher
costs than the other options available to you. While we typically offer a broader range of investment options and services than
an employer-sponsored QRP, there are no guarantees that the additional investment options will outperform your employer-
sponsored QRP.

The online process for opening an Intuitive Investor Account does not provide any recommendations or advice with respect to
the rollover or transfer of any retirement Account or IRA to Intuitive Investor.

593718 (Rev 16 - 05/22) Page 19 of 23

Order Flow. We may receive additional compensation in the form of order flow payments from options trades executed
through smart routers. In addition we may receive compensation from equity orders routed to national exchanges for
execution. Please refer to the "Fees and Compensation" section for a discussion of additional fees that you may incur.

Best Execution Committee. We have a Best Execution Committee that reviews trading activity and the vendors and
systems we use to process transactions, among other things. Both advisory Client and non-advisory brokerage trades orders
are treated with the same priority and procedural flow, except to accommodate the trading restrictions placed on these
Accounts with respect to principal trades and agency cross-transactions.

To seek a more advantageous net price, it is our practice to aggregate orders, when feasible, for the purchase (or sale) of a
particular security for the Accounts of several Program Clients for execution as a single transaction. Any benefit of such
aggregation generally is allocated pro-rata among the Client Accounts that participated in the aggregated transaction.

Client transactions are monitored regularly by branch supervisors, and product management personnel monitor Program
exceptions as part of their general oversight responsibility for the Programs. In addition, we use system controls and
identification to restrict advisory Accounts from being charged commissions. We also regularly review reports to determine if
you have been charged commissions in error and correct Accounts where appropriate.

Order Handling. The securities traded for you may be traded in one or more marketplaces or may employ an alternative
trading system ("ATS") to execute fixed income transactions. Consistent with the overriding principle of best execution and
subject to applicable regulatory requirements, we may use our discretion in selecting these marketplaces or ATSs to enter or
execute your orders.

We route Client orders for over-the-counter equities and listed equity securities to execution venues as appropriate, including
our affiliate, with best execution being the highest priority.
• We consider a number of factors when determining where to send Client orders, including execution speed and
price, price improvement opportunities, the availability of efficient and reliable order-handling systems, the level of
service provided, and the cost of executing orders.
• We strive to execute all held orders at prices equal to or better than the displayed national bid/offer price, up to the
displayed size, at the time of execution.
• Not-held orders are worked for best price by the trading desk. We may utilize non-affiliated third-party Authorized
Participants ("APs") when transacting large blocks of ETFs. APs are typically large institutions like market makers
or specialists who can create ETFs by trading the underlying securities.

As a result of the over-the-counter nature (the lack of a market exchange) of fixed income securities, the available trading
methods differ from that of equity securities. Consistent with the overriding principle of best execution and subject to
applicable regulatory requirements, we may use our discretion in selecting the appropriate ATS and/or broker-dealers with
which to execute Client orders. We consider a number of factors when determining where to execute Client orders, including
the product type (which may influence the liquidity in the market) and the size of the order.

For both equity and fixed income securities, we regularly review transactions for quality of execution, and take action, as
appropriate, for price improvement and to fulfill our best execution obligations. At all times, our foremost concern is to obtain
the best execution for our Clients, regardless of any compensation factor.

If any such prices are unavailable or believed to be unreliable, we will determine prices in good faith so as to reflect our
understanding of fair market value.

Margin Loans and Securities-Based Loan Programs

You may be eligible to use margin in your non-retirement Accounts or pledge your non-retirement Account assets as collateral
for margin loans ("Margin Loans"). You may also be able to pledge your non-retirement Account assets as collateral for loans
obtained through certain affiliated and unaffiliated loan programs ("Securities-Based Loan Programs"). It is important that you
fully understand the costs, risks, and conflicts of interest involved in pledging your Account assets for a Margin Loan or
Securities-Based Loan.

Margin Loans

Certain Advisory Programs may permit margin borrowing and trading. We will not extend margin in an advisory account
unless authorized by you through a separate margin agreement. You are responsible for notifying us if you decide that you no
longer want to use margin in your Account. You may also discontinue use of margin in your Account according to the terms of
the Client Agreement. We are not responsible for any losses resulting from our failure or delay in implementing such
instructions.

593718 (Rev 16 - 05/22) Page 20 of 23

 • Margin Loans Are Subject to Separate Terms and Conditions. If you take out a Margin Loan, the terms and
conditions applicable to the Margin Loan are governed by the Margin Disclosure Statement and the Client
Agreement. You should review carefully the terms, conditions, and risk disclosures for Margin Loans and
understand that such risks are heightened in the event you hold a concentrated position in your pledged Account
or if your pledged Account makes up all, or substantially all, of your overall net worth or investable assets. Certain
eligibility requirements must be met, and documentation in the form of a separate margin agreement must be
completed prior to using margin.
• Costs Are in Addition to Advisory Fees. As discussed above, if you use margin to purchase additional securities,
your Account Value increases and therefore the amount of fees you pay will increase. You will also be charged
margin interest on the debit balance in your Account, which is in addition to the Program Fee and Platform Fee.
This results in additional compensation to us. The interest charged on a Margin Loan is higher than the interest
charged on affiliated Securities-Based Loans, including Priority Credit Line.
• We Have an Incentive to Recommend the Use of Margin. The increased asset-based fee and interest that you pay
on a Margin Loan provides an incentive for your Financial Advisor to recommend the use of margin. Your Financial
Advisor also has an incentive to use margin to purchase additional securities and other assets instead of selling
existing securities or other assets. We address these conflicts by disclosing them to you.
• Margin Loans May Not Be Suitable for You. Using margin is not suitable for all investors. As described in the next
paragraph, the use of margin increases leverage in your Account and therefore increases risk to a portfolio. We
generally believe the use of margin is most appropriate when short in duration. Before deciding to use margin, you
should consider the intended duration and total cost of the Margin Loan, as well as other options available to you,
such as alternative loan options or liquidating your Account assets.
• Using Margin Involves Higher Risks. Generally, we believe that the use of margin adds risk to a portfolio that you
should not assume unless you are prepared to experience significant losses. Losses in the value of an asset
purchased on margin will be magnified because of the use of borrowed money. You can lose more funds than
amounts deposited in margin accounts. In addition, you generally will not benefit from using margin unless the
performance of your Account exceeds interest expenses on the Margin Loan plus advisory fees incurred. You
should also understand that the use of margin can negatively impact our ability to rebalance your account. You
should carefully consider whether the additional risks are appropriate prior to using margin due to the increased
potential for significantly greater losses associated with using margin. You assume full responsibility for the use of
margin in your Account. Please see the Margin Disclosure Statement and the Client Agreement for more
details on the risks of margin use. You should read this documentation carefully.

Securities-Based Loan Programs

You may pledge your Account assets as collateral for Securities-Based Loan Programs with our consent and where you are
eligible under the programs. The Securities-Based Loan Programs include, but are not limited to, the Priority Credit Line
("PCL") from Wells Fargo Advisors and various loan programs from our affiliate Wells Fargo Bank, N.A. ("Wells Fargo Bank").
The Secured PrimeLine program is available only in limited circumstances. In order for your Account to be eligible to serve as
collateral for a Securities-Based Loan, your Account may not also serve as collateral for a Margin Loan. If you wish to use
your Account as collateral for a Securities-Based Loan, we will automatically discontinue the availability of margin for your
Account.

There are risks, costs, and conflicts of interests associated with Securities-Based Loan Programs. You are encouraged to
speak with your Financial Advisor to the extent you have questions about how your Account may be used in connection with a
Securities-Based Loan Program and how such arrangement should be taken into consideration when discussing the
management of your Account.
• Securities-Based Loan Programs Are Subject to Separate Terms and Conditions. If you have elected to participate
in a Securities-Based Loan Program, the terms and conditions applicable to that Securities-Based Loan Program
are governed by the applicable Securities-Based Loan documents and other service agreements and are not
included or described further in this brochure. You should review carefully the terms, conditions and any related
risk disclosures for the Securities-Based Loan Program and understand that risks are heightened in the event you
hold a concentrated position in your pledged Account or if your pledged Account makes up all, or substantially all,
of your overall net worth or investable assets. You should understand that PCL provides more favorable protection
for us in the event of your bankruptcy than loan programs through Wells Fargo Bank. Certain eligibility
requirements must be met and documentation must be completed prior to obtaining Securities-Based Loans.
• Interest Rates for Securities-Based Loan Programs Differ. In certain circumstances, more than one Securities-
Based Loan Program product may be available to you. The interest rate charged for PCL may be higher than
interest rates available through other loan programs from Wells Fargo Bank and unaffiliated lenders. PCL is
generally more profitable for us than other loan programs from Wells Fargo Bank, and gives us an incentive to
recommend PCL over Securities-Based Loan Programs at Wells Fargo Bank.

593718 (Rev 16 - 05/22) Page 21 of 23

 • Costs Are in Addition to Advisory Fees. The costs, including interest, associated with a Securities-Based Loan
Program are not included in the Program Fee or Platform Fee and will result in additional compensation to us, our
affiliate, and our Financial Advisors. The interest charges on your Securities-Based Loan Program, combined with
the Program Fee and Platform Fee, may exceed the income generated by your pledged Account assets and, as a
result, the value of your Account may decrease. You are encouraged to consider carefully the total cost of taking
out a Securities-Based Loan, and any additional compensation that WFA and your Financial Advisor will receive,
when determining to take out and/or maintain a Securities-Based Loan against your Account assets.
• Financial Advisors Receive Compensation on Securities-Based Loans. In addition to receiving a portion of the
Program Fee, Financial Advisors also receive compensation based on the outstanding loan balances of PCL and
Securities-Based Loan Programs from Wells Fargo Bank. The Financial Advisor's compensation is reduced if the
interest rate on PCL or a Securities-Based Loan from Wells Fargo Bank is discounted below a certain level, which
creates an incentive for the Financial Advisor to not request for you or to discourage interest rate discounts below
a certain level.
• We Have an Incentive to Recommend the Use of Securities-Based Loan Programs. Since WFA and your Financial
Advisor are compensated through asset-based advisory fees paid on your Account, we benefit if you draw down
on your Securities-Based Loan, which preserves asset-based advisory fee revenue and generates additional loan-
related compensation, rather than sell securities or other investments in your Account, which would reduce the
assets in your Account and our asset-based advisory fee revenue. This presents a conflict of interest for your
Financial Advisor when addressing your liquidity needs. In addition, where a Securities-Based Loan is secured by
both brokerage and advisory assets, a Financial Advisor will benefit if your brokerage assets are liquidated prior to
or instead of your advisory assets because the Financial Advisor would be able to maintain advisory Account
assets subject to the Program Fee and Platform Fee. We address these conflicts by disclosing them to you.
• Securities-Based Loan Programs May Not Be Suitable for You. There are other lending products that may be
suitable for you and for which we and your Financial Advisor would receive different or no compensation. You are
responsible for independently evaluating if a Securities-Based Loan is appropriate for your needs, if the lending
terms are acceptable, and whether the Securities-Based Loan will have potential adverse tax or other
consequences for you.
• There Are Limitations on the Use of Securities-Based Loan Proceeds. Except for margin accounts, where the loan
proceeds can be used to purchase, carry, or trade securities, the proceeds of PCL may not be used to (a)
purchase, carry, or trade securities or (b) reduce or retire any indebtedness incurred to purchase, carry, or trade
securities. If your Account is used as collateral for a Securities-Based Loan, the Account is pledged to support the
Securities-Based Loan and you are not permitted to withdraw funds or other assets from your Account unless
sufficient amounts of collateral remain to continue supporting the Securities-Based Loan (as determined under the
applicable Securities-Based Loan Program). Although you are required to satisfy such collateral requirements, you
can terminate your advisory relationship with WFA, at which time the funds and assets in your account will be
treated as a brokerage account at WFA and the collateral requirements for the Securities-Based Loan will continue
to apply.

Additional Considerations Associated with Pledging Advisory Account Assets for Margin Loans and Securities-
Based Loans

In addition to the risks mentioned above, if your Account assets are pledged or otherwise used as collateral for Margin Loans
or Securities-Based Loans, the exercise of our rights and powers over your Account assets, including the disposition and sale
of any and all assets pledged as collateral, may be contrary to your interests and the investment objective of your Account.
• There Are Collateral Maintenance Requirements. When you use margin to purchase securities or draw down on a
Securities-Based Loan, your Account assets serve as collateral. We can increase our "house" maintenance
requirements or call your Margin Loan or PCL at any time and for any reason, and are not required to provide you
with advance written notice (although these approaches will be different for loan programs from Wells Fargo Bank,
and may be different for loans from unaffiliated lenders). If your Account assets decline in value, so does the value
of the collateral. If the required collateral is not maintained, you may need to deposit additional cash or securities
as collateral or repay a partial or entire amount of the funds borrowed on short notice. You are not entitled to an
extension of time on a margin call. The lender may refuse to fund any advance request due to insufficient
collateral. Where the lender assigns different release rates to different asset types, you may be able to satisfy
collateral maintenance requirements by selling securities with a low release rate and investing and/or holding the
proceeds in assets that have a higher release rate for the loan.

593718 (Rev 16 - 05/22) Page 22 of 23

 • Liquidation of Securities in a Maintenance Call. Failure to promptly meet requests for additional collateral or
repayment, or other circumstances including but not limited to a rapidly declining market, will cause the liquidation
of some or all of the collateral supporting any Margin Loans or Securities-Based Loans in order to meet the
maintenance requirements. We can sell your Account assets without contacting you. We are not required to notify
you of a maintenance call. These approaches will be different for loan programs from Wells Fargo Bank, and may
be different for loans from unaffiliated lenders. You will be responsible for any shortfall if your Account assets are
insufficient to cover the maintenance deficiency. Even if we have notified you and provided a specific date by
which you can meet a maintenance call, we can still take necessary steps to protect our financial interests,
including immediately selling your Account assets without notice to you. You should understand that because your
Account assets are collateral for the Margin Loans or Securities-Based Loans, in selling such assets, we will seek
to protect or advance our interests (and/or those of our affiliated lender if you selected an affiliated Securities-
Based Loan Program) over your interests. You should expect that our interests will not be aligned with─and will be
adverse to─your interests when we sell assets during a maintenance call, and that we may sell assets that you
desire to keep or sell them at prices that may be less than the value that we or you believe the assets are worth.
You are not entitled to choose which Account assets are liquidated or sold to meet a maintenance call. If there are
Account assets that you desire to own during the term of your Margin Loan or Securities-Based Loan, you should
not pledge them as collateral. Depending on market circumstances, the prices obtained for your Account assets
may be less favorable and may be less than the value that we or you believe the assets are worth. If a margin or
maintenance call cannot be fully satisfied from your Account assets, you remain liable for the outstanding debt.
• Impact of Margin and Maintenance Calls on Management of Your Account. In a maintenance call, we might
liquidate Account assets that you, your Financial Advisor, or your Manager otherwise would not sell, and that might
not otherwise be in your best interests to sell, and you might not get to choose the assets that are liquidated. We or
a third-party Manager will seek to manage your Account as agreed under your advisory Client Agreement and
applicable Program Features and Fee Schedule, provided that, if a maintenance call takes place, you should
expect that we or your Manager will not be able to manage your Account consistent with our or the Manager's
overall strategy. In addition, in order to preserve sufficient collateral value to support the loan and avoid a
maintenance call, depending on your leverage, a Financial Advisor may be inclined to invest your Account in more
conservative investments, which may result in lower investment performance than more aggressive investments
(depending on market conditions). We mitigate this risk by requiring and monitoring to ensure that your Account is
managed consistent with your respective investment strategies.
• No Legal or Tax Advice. WFA and your Financial Advisor do not provide legal or tax advice. You should consult
with your own legal counsel and independent tax advisor before using securities as collateral for loans in order to
fully understand the tax implications associated with pledging your Account as loan collateral and the potential
liquidation of pledged assets.

Privacy. We will not sell your information to other companies for marketing purposes. We employ strict security standards
and safeguards to protect your personal information and prevent fraud. In addition, we will continue to protect your privacy
even if you are no longer our Client.

Consistent with our privacy policies and applicable law, WFA and its affiliates may provide access to Client personal
information to affiliated and third party service providers throughout the world. When Client information is accessed, we
maintain protective measures as described in our privacy policies and notices. For more information, please see our Privacy
Statement.

For more information, please read our Privacy Statement or call (855) 283-5567. With your written permission, obtained via
Client Agreement or other written communication, we may provide your information electronically to your investment adviser
and/or agent of such adviser. We reserve the right, at our discretion, to refuse to provide such requested information.
Furthermore, in compliance with our Privacy Policy, we accept your instructions to discontinue providing such information.

Financial Information

We have no financial condition that is likely to impair our ability to meet our contractual commitments to you.

593718 (Rev 16 - 05/22) Page 23 of 23

 SEC FORM ADV PART 2A:
FIRM BROCHURE
March, 2022

SigFig Wealth Management, LLC

100 N. Stone Avenue, Suite 110
Tucson, AZ 85701
Tel: 415-558-9611
www.sigfig.com

ITEM 1 Cover Page

This brochure ("Brochure") provides information about the qualifications and business practices of
SigFig Wealth Management, LLC ("SigFig"). If you have any questions about the contents of this
Brochure, please contact us at support@sigfig.com or by telephone at 415-558-9611. 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. Any references in this Brochure to SigFig as a
"registered investment adviser" are not intended to imply a certain level of skill or training.

593719 (Rev 09 - 03/22) Page 1 of 28

 ITEM 2
MATERIAL CHANGES
Since the last updating amendment to SigFig’s Form ADV Part 2 brochure on March 29, 2021,
material and other changes to this Brochure include amendments to the following items:

Item 4 - Advisory Business

• Updated disclosure regarding SigFig's sub-advisory arrangements with Financial
Institutions.
• Disclosure added regarding SigFig's advisory services to evaluate, engage and perform
ongoing monitoring of third-party investment managers who provide SigFig with model
portfolios that will be recommended to Digital Advice Investors.

• Assets under management was updated to reflect assets under management as of

December 31, 2021.

Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss

• Disclosure added regarding processes for addressing trade and operating errors.

Item 14 - Client Referrals and Compensation

• Updated disclosure to align with the rule amendment governing solicitation arrangements.

This Brochure provides important information about the qualifications and business practices of
SigFig Wealth Management, LLC. We encourage you to read this Brochure in its entirety.
Additional information about SigFig is available on the SEC's website at www.adviserinfo.sec.gov.

593719 (Rev 09 - 03/22) Page 2 of 28

ITEM 3
TABLE OF CONTENTS
SEC FORM ADV PART 2A:
FIRM BROCHURE ................................................................................................................................................. 1

ITEM 2
MATERIAL CHANGES .......................................................................................................................................... 2

ITEM 3
TABLE OF CONTENTS ......................................................................................................................................... 3

ITEM 4
ADVISORY BUSINESS ......................................................................................................................................... 4

ITEM 5
FEES AND COMPENSATION ............................................................................................................................... 7

ITEM 6
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................................. 9

ITEM 7
TYPES OF CLIENTS ............................................................................................................................................. 10

ITEM 8
METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ................................................ 11

ITEM 9
DISCIPLINARY INFORMATION ............................................................................................................................ 18

ITEM 10
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ..................................................................... 19

ITEM 11
CODE OF ETHICS, PARTICIPATION, OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ............................................................................................................................................................... 20

ITEM 12
BROKERAGE PRACTICES ................................................................................................................................... 22

ITEM 13
REVIEW OF ACCOUNTS ...................................................................................................................................... 23

ITEM 14
CLIENT REFERRALS AND COMPENSATION ..................................................................................................... 24

ITEM 15
CUSTODY .............................................................................................................................................................. 25

ITEM 16
INVESTMENT DISCRETION ................................................................................................................................. 26

ITEM 17
VOTING CLIENT SECURITIES ............................................................................................................................. 27

ITEM 18
FINANCIAL INFORMATION .................................................................................................................................. 28

593719 (Rev 09 - 03/22) Page 3 of 28

 ITEM 4
ADVISORY BUSINESS
A. General Description of Advisory Firm
SigFig Wealth Management, LLC ("SigFig") is a limited liability company that was founded in 2011
and is an SEC-registered investment adviser. SigFig is a wholly-owned subsidiary of Nvest, Inc.

B. General Description of Advisory Services Offered

1. Investment Advisory Services
SigFig provides free portfolio tracking service to individuals ("Users") by allowing them to link their
external brokerage accounts to SigFig’s web-based platform1.
Utilizing its proprietary web-based technology, SigFig also provides discretionary investment
advisory and portfolio management services to individuals who open an investment management
account with SigFig (the "Clients") and enter into an investment advisory agreement ("Investment
Advisory Agreement"). SigFig’s algorithms generate investment recommendations based on such
Client’s risk profile, trading patterns, and existing individual portfolio investments, if any. SigFig’s
advisory services are made available to Clients through its website at www.sigfig.com, mobile
apps and through co-branded pages and widgets on its media partners’ websites (collectively the
"Website"). In all cases, including those where the services are made available through a co-
branded partner website, SigFig’s web-based platform is powering the investment advisory
services and hosting Client data.
SigFig’s online platform allows Users and Clients to:
• Sync portfolio data from the existing brokerage accounts and review it holistically in an easily
accessible interface;
• Track and analyze holdings;
• Receive real-time and delayed market data and news on securities in their portfolios;
• Calculate portfolio performance and other analytics;
• Receive analysis and/or recommendations on their trading style and trading behaviors; and
• Create and edit mock portfolios and watch lists.
In addition, Users who are also advisory Clients of SigFig can:

• Use tax-loss harvesting feature2; and

• Receive analysis and/or recommendations of mutual funds and exchange-traded funds
(“ETF’s”) based on their answers to a risk profile questionnaire, existing investment portfolio
and transaction history, if any.
1. It should be noted that Users do not enter into an investment agreement with, nor do they pay fees to, SigFig. Further, SigFig does not have any
discretion over Users’ brokerage accounts, nor does SigFig provide recommendations to Users to purchase or sell any specific securities. For the
aforementioned reasons, Users are not considered advisory clients of SigFig.

2. Tax-loss harvesting is a process that aims to realize losses to offset gains made within the portfolio. SigFig does not provide comprehensive
tax advice.

593719 (Rev 09 - 03/22) Page 4 of 28

As noted above, SigFig’s technology enables Users and Clients to import their external accounts
data securely onto SigFig’s secure user platform. Users and Clients then have the ability to see
their entire synced portfolio in one place, irrespective of which and how many SigFig-supported
brokerage firms they use. Based on numerous factors, including but not limited to risk-adjusted
performance, fees and similarity, SigFig’s analysis and recommendations (in the case of Clients)
have been designed to enable Users and Clients to optimize their existing synced portfolios and
reduce their brokerage costs. Users must make an independent determination as to whether to
follow any guidance provided through the SigFig Website, and must make their own arrangements
for execution of any desired transactions, the hiring of any investment adviser or the use of any
broker-dealer.
SigFig currently provides investment advice only with respect to mutual funds, ETF’s (collectively,
"Securities") and tax-loss harvesting. As part of its services, SigFig also recommends broker-
dealers to Clients. SigFig’s advice is currently intended to be limited to the foregoing.
2. Sub-Advisor, Portfolio Manager and Service Provider Services

Additionally, SigFig enters into partnerships with various Financial Institutions that may be
registered investment advisers, banks, or broker-dealers (the “Financial Institutions” or “Partners”).
Under these arrangements, SigFig licenses its proprietary web-based technology to the Financial
Institutions acting as a service provider to the respective Partner and, depending on the
partnership, may serve as the sole adviser to the Clients referred by the Partner (as described in
Item 14 of this Brochure) or as a sub-advisor and portfolio manager to the Partner and its clients.
The sub-advisory and portfolio management services are provided by SigFig through the use of its
proprietary software, and a website operated and hosted by or on behalf of SigFig by the
respective Financial Institution for the benefit of those clients of the Financial Institutions ("Digital
Advice Investors") who elect to receive such investment advisory services (the "Digital Advice
Program"). In the case of such sub-advisory and portfolio management services, SigFig generates
and implements investment recommendations based on the information and specifications
provided to it by the prospective Digital Advice Investors or the Financial Institution.
In this capacity, SigFig’s services are currently limited to the following:
a. Provide to prospective Digital Advice Investors a risk profile questionnaire (as prepared by the
Partner, or as developed by SigFig and approved by the Partner) that will serve as the basis for
the investment recommendations;
b. Generate and/or present investment recommendations to each prospective Digital Advice
Investor as provided to SigFig from the Financial Institution or based on the parameters
determined or approved by the Financial Institution;
c. Implement, on a discretionary basis, such recommendations once the prospective Digital
Advice Investor has opened a Digital Advice Program account with the Financial Institution;
d. Manage Digital Advice Investor accounts in accordance with the investment portfolios
developed or approved by the Financial Institution; and
e. Implement tax-loss harvesting strategies in the accounts of Digital Advice Investors who
opted to take advantage of this capability based upon preset criteria and specifications
determined or approved by the Financial Institution.
f. Evaluate, engage and perform ongoing monitoring of third party investment managers
("Model Providers") who provide SigFig with model portfolios approved by the Financial
Institution that will be recommended to Digital Advice Investors ("Model Portfolios").
593719 (Rev 09 - 03/22) Page 5 of 28
 The Financial Institution sponsoring and offering its Digital Advice Program determines which
services of SigFig to utilize with the Digital Advice Investors and may utilize the services of other
third-party or affiliated service providers in conjunction with the Digital Advice Program. Digital
Advice Investors should therefore consult the Financial Institution's Brochure for a fuller
description of the specific use of SigFig's services and any other important information about the
respective Digital Advice Program.
C. Tailoring of Advisory Services and Client Imposed Restrictions
SigFig provides guidance as part of portfolio-tracking services to Users based on their existing
portfolio data (as provided to SigFig by the User via the accounts linked onto SigFig’s User
Platform) and answers to the risk tolerance questionnaire.
With respect to advisory and sub-advisory services, SigFig tailors such services to the Clients’ and
Digital Advice Investors’ respective investment objectives and risk tolerance, as communicated to
SigFig by the Clients’ and Digital Advice Investors’ or, in case of certain Digital Advice Programs,
generates and implements investment recommendations based on the information and
specifications provided to it by the Financial Institution.

Clients and Digital Advice Investors are responsible for updating the information provided to
SigFig (and the Financial Institutions in the context of Digital Advice Programs) in the event there
are changes to their investment objectives, risk tolerance or any other information provided
through the risk profile questionnaire.

SigFig bases its advice to Clients and Digital Advice Investors on the investment objectives and
restrictions set forth in the applicable investment management agreement, digital advisory
services schedules and terms of use, as the case may be. In addition, in formulating the
investment recommendations for Clients and Digital Advice Investors’ accounts or implementing
the investment recommendations provided and communicated to SigFig by the Partner, the
Financial Institutions and SigFig will comply with the reasonable restrictions imposed by the
Clients and Digital Advice Investors, which may include the designation of securities that should
not be purchased or held in the Clients’ or Digital Advice Investors’ accounts.
• If SigFig, in consultation with the Financial Institution (in case of Digital Advice Programs),
believes that the restrictions requested by a Client or Digital Advice Investor are unreasonable
or inappropriate, SigFig will notify Client or the Financial Institution will notify the Digital Advice
Investor that, unless the restrictions are modified, the account will be removed from the
respective program.
• Clients and Digital Advice Investors will not be able to impose restrictions that prohibit or
restrict the purchase of ETFs.
Clients and Digital Advice Investors are strongly encouraged to consider their individual
circumstances, risk tolerance, and needs prior to following any investment recommendation.
The Digital Advice Programs offered through SigFig’s partnerships with certain Financial Institutions
may be offered as a wrap fee program for which more information can be found in the relevant
Financial Institution’s Brochure.

D. Assets Under Management

As of December 31, 2021, SigFig managed approximately $2,301,052,950 of Client and Digital
Advice Investors' assets on a discretionary basis. SigFig does not currently manage any assets in a
non-discretionary capacity.
593719 (Rev 09 - 03/22) Page 6 of 28
ITEM 5
FEES AND COMPENSATION
A. Fees and Compensation
SigFig’s sources of revenue include advertising revenue generated through media partnerships, and
management fees charged to the Clients. SigFig delivers portfolio-tracking services without charge
to Users. Clients are charged a flat fee or a percentage of the Client’s assets under management.
The management fee is generally no greater than .50% of assets under management. Clients
should refer to the Investment Advisory Agreement for the detailed fee schedule.
In addition, with respect to the Digital Advice Programs offered through the partnerships with certain
Financial Institutions, SigFig’s sources of revenue include a portion of the management fees
charged to Digital Advice Investors by the Financial Institutions based on assets under management
(the “Variable Fee”), as well as digital platform licensing, hosting and maintenance fees paid by the
respective Financial Institution to SigFig. The Variable Fee is negotiated between SigFig and each
Financial Institution and generally ranges from .025% - .10% of assets under management
assessed monthly or quarterly. SigFig’s agreement with its Partners may guarantee SigFig a
minimum monthly, quarterly, or annual amount of management fees, such that the Financial
Institution guarantees a minimum level of management fee revenues to SigFig, irrespective of
whether the total management fees billed by the Financial Institution to the Digital Advice Investors
or SigFig’s agreed upon share thereof meets or exceeds that minimum.
Clients and Digital Advice Investors should pay particular attention to Item 5.C. below which
describes other fees, not charged by SigFig or the respective Financial Institutions, that they may
incur from third parties.
B. Fee Deduction
Management fees are deducted from Client accounts by the account custodian and are paid
generally monthly, in arrears in accordance with the Investment Advisory Agreement.

In the context of Digital Advice Program, SigFig is compensated directly by the Financial Institution.
Management fees are deducted from Digital Advice Investors’ accounts by the Financial Institution
in accordance with the relevant Investment Advisory Agreement between the Financial Institution
and the Digital Advice Investor. Digital Advice Investors should refer to the relevant Financial
Institution’s Brochure for more information regarding management fees charged in the respective
Digital Advice Program.
C. Other Fees and Expenses
Clients and Digital Advice Investors may incur certain other standard fees and expenses billed by
third parties. Such costs could include brokerage commissions, account opening fees, transaction
fees, custodian fees, investment adviser fees and other related costs and expenses that will be
incurred directly by the Client or Digital Advice Investor.
Clients and Digital Advice Investors should carefully review their Investment Advisory Agreements
with SigFig or the respective Financial Institution for disclosures around fees.

593719 (Rev 09 - 03/22) Page 7 of 28

 D. Compensation for the Sale of Securities or Other Investment Products
As noted elsewhere in this Brochure, investment recommendations made by SigFig and the
Financial Institution in the context of the Digital Advice Programs will, in certain cases, be executed
by broker-dealers affiliated with the Financial Institution. As such, when the Digital Advice
Investors’ trade execution is directed to an affiliated broker-dealer, Digital Advice Investors may
not obtain rates as low as they might otherwise obtain if a different broker-dealer were to be used.
Also, such arrangements may cause the affiliated broker-dealer to earn additional compensation
(such as clearing and custody payments). This practice presents a conflict of interest and gives
SigFig or the Financial Institution an incentive to recommend investment products based on the
compensation received, rather than on the Digital Advice Investor’s needs. Digital Advice
Investors are encouraged to review the relevant Financial Institution’s Brochure for more
information.
SigFig addresses these conflicts of interest in numerous ways, including, but not limited to, the
following:

a. SigFig conducts due diligence on the broker-dealers that it implicitly or explicitly recommends
to Clients or Digital Advice Investors and seeks to ensure that the basis upon which SigFig
purports to make its recommendation is accurate to the best of its knowledge when the
recommendation is given.
b. In all cases, SigFig seeks to provide Clients and Digital Advice Investors with disclosures that
it believes would enable them to make informed decisions as to whether they should follow
the recommendations provided.
c. As a fiduciary, SigFig has the obligation to seek "best execution" when trades are placed with
broker-dealers. Best execution entails the efficient placement of orders, clearance, settlement,
and the overall quality of execution as well as the cost of the transaction.
d. SigFig, in cooperation with the Financial Institutions, to whom it acts as a sub-adviser,
monitors transaction results as orders are executed to evaluate the overall quality of
execution provided by brokers-dealers used.
e. SigFig discloses in this Brochure that Clients and, in some cases, Digital Advice Investors
have the option to choose to request to set up brokerage and custodial relationship with one
of the broker-dealers with whom SigFig has an established relationship.

593719 (Rev 09 - 03/22) Page 8 of 28

ITEM 6

PERFORMANCE-BASED FEES AND SIDE-BY-

SIDE MANAGEMENT
SigFig does not charge performance-based fees. Clients and Digital Advice Investors are only
charged a management fee as disclosed in Item 5.

593719 (Rev 09 - 03/22) Page 9 of 28

 ITEM 7
TYPES OF CLIENTS
SigFig Clients and Digital Advice Investors are generally individual investors who are seeking to
optimize their investment portfolio, reduce their transaction costs, and/or hire an investment
adviser. Clients and Digital Advice Investors are not required to have a certain amount of
investment experience, personal wealth or sophistication. SigFig generally imposes a $2,000
minimum investment on the Clients, which can be reduced or waived in SigFig’s sole discretion.
Digital Advice Programs may also impose minimum investment requirements. Digital Advice
Investors should refer to the relevant Financial Institution’s Brochure for information regarding
investment minimum requirements.
Prior to receiving investment advice from SigFig, prospective Clients are required to open an
account on SigFig’s online platform. To register an account, a prospective Client is required to
provide SigFig with:
• Identifying Information (e.g., email and password);
• Information regarding the Client’s existing investment portfolios, if any (either by providing
SigFig with accounts credentials, so that SigFig can directly obtain Client account holdings or
by inputting the account information manually);
• Responses to a profile questionnaire in order to determine which investment
recommendations that should be provided to the Client;
• An agreement to SigFig’s Terms of Service; and
• An acknowledgment and agreement to SigFig’s Privacy Policy.

It should be noted that certain of SigFig’s information services are accessible without registering a
user account. Such services do not involve the provision of investment advice.
Similarly, prior to receiving investment advice from the Financial Institution and SigFig, Digital
Advice Investors are required to open a Digital Advice Program account and provide the Financial
Institution and SigFig with:
• Identifying Information (e.g., email and password);
• Responses to a profile questionnaire – designed by SigFig and reviewed and/or approved by
the Financial Institution – in order to determine which investment recommendations that
should be provided to the Digital Advice Investor;
• An agreement to the Financial Institution’s Terms of Service; and
• An acknowledgment and agreement to the Financial Institution’s and, in certain cases,
SigFig’s Privacy Policy.

593719 (Rev 09 - 03/22) Page 10 of 28

ITEM 8
METHODS OF ANALYSIS, INVESTMENT
STRATEGIES, AND RISK OF LOSS
A. Methods of Analysis and Investment Strategies
As described in Item 4.B, SigFig provides the investment advice and portfolio management
services to Clients and Digital Advice Investors using its proprietary web-based software and the
Website. With respect to the Digital Advice Programs, the Website is operated and hosted by or
on behalf of SigFig by the relevant Financial Institution and investment recommendations to each
prospective Digital Advice Investor are formulated or reviewed and approved by the Financial
Institution.
In those partnerships that offer a Digital Advice Program, all analytical methodology, investment
strategy determination, model portfolio construction, security selection within each asset class,
and the configuration of parameters for tax-loss harvesting strategies are determined by the
Financial Institution and delivered through SigFig’s Digital Advice Platform. Digital Advice
Investors should refer to the relevant Financial Institution’s Brochure for detailed information on
methods of analysis and investment strategies used within the Digital Advice Program offered
through SigFig’s partnership with such Financial Institution.
SigFig’s investment methodology is based on a rigorously researched portfolio management
framework:
1. SigFig researches assets class options to understand their performance in different market
and economic conditions by analyzing class returns, volatility, and correlation among the
classes and identifies which asset classes contribute to a well-balanced portfolio;
2. Further, SigFig selects investment vehicles that it believes provide the balance of market
coverage at lower cost;

3. SigFig creates portfolios matched to a range of risk tolerances through the Modern Portfolio
Theory ("MPT") techniques. MPT attempts to maximize a portfolio’s expected return for a
given amount of portfolio risk, or equivalently minimize risk for a given level of expected
return, by selecting the proportions of various asset classes rather than selecting individual
securities. By investing in various asset classes, i.e., diversifying, an investor can potentially
reduce the overall riskiness of the portfolio. Picking a specific mix of asset classes for a
particular investor depends on such individual’s risk tolerance and requires a technique
known as mean-variance optimization, which is an analysis of the expected performance,
variability, and correlation of each asset class based on observations over the last twenty
years, weighted towards more recent history. This results in a series of portfolios that are
designed to have the least amount of risk for various levels of return. However, this analysis is
based on the forward-looking projections that are inherently uncertain and there is no
guarantee that any given portfolio will meet its objectives.

4. In the risk profile questionnaire, we ask Clients and Digital Advice Investors a set of questions
to develop an understanding of their goals and preferences to balance the riskiness of
investing with expected returns;

5. SigFig monitors and, if needed, rebalances Clients’ and Digital Advice Investors’ portfolios to
maintain the model asset allocation.
593719 (Rev 09 - 03/22) Page 11 of 28
 SigFig’s proprietary software platform generates investment recommendations based on the
Client’s or Digital Advice Investor’s risk profile. The risk profile is built using the information about
Client’s or Digital Advice Investor’s age, time horizon, income, liquid assets, estimated percentage
of household income saved, and risk tolerance provided by them in the risk profile questionnaire
through the Website. As mentioned elsewhere in this Brochure, the risk profile questionnaire in the
Digital Advice Programs may be generated by the Partner or developed by SigFig and approved
by the Partner.
In addition, SigFig makes a guidance application ("Guidance Application") available to Users,
Clients and Digital Advice Investors in certain Digital Advice Programs, which allows them to sync
their existing investment accounts onto SigFig’s or respective Digital Advice platform and
performs an analysis of these accounts. The synced portfolios data is analyzed against the
recommended portfolio based on certain criteria, such as volatility, stock/bond split, expense ratio,
amount of cash maintained in the account, geographic diversification and single stock exposure,
and provides the User, Client or Digital Advice Investor guidance on how they could optimize their
existing portfolio. In the Digital Advice Program context, the Financial Institutions can elect not to
use the Guidance Application or have it perform the analysis on (a) accounts maintained with the
Financial Institution and its affiliates; or (b) on accounts maintained with the Financial Institution
and its affiliates and third-party financial services providers.
SigFig’s algorithms also assess and try to optimize potential tax impact when transitioning the
Client’s or Digital Advice Investor’s existing portfolio into the recommended portfolio and perform
ongoing tax efficiency management when executing trades in the Clients’ and Digital Advice
Investors’ accounts. Clients and Digital Advice Investors should not construe the contents of the
Website or any recommendation made by SigFig as tax advice. Each Client and Digital Advice
Investor must rely upon its own representatives as to tax and other aspects of an investment in
securities and as to its suitability for such Client or Digital Advice Investor.
SigFig’s proprietary algorithms are overseen by SigFig’s Investment Committee, which
determines SigFig’s investment strategy, reviews the securities used in Client and Digital Advice
Investor portfolios, and has the authority to institute necessary measures, such as halting trading,
in adverse market conditions.
As noted above, SigFig provides portfolio guidance and portfolio tracking services to Users. The
Users must make their own investment decisions based on the guidance and supporting
information provided. Clients with accounts in SigFig’s paid investment management service give
SigFig discretionary authority to direct, manage, and change the investment and reinvestment of
the Client’s assets. Digital Advice Investors with accounts in certain Digital Advice Programs give
the partner Financial Institution, with SigFig as sub-adviser and portfolio manager, discretionary
authority to direct, manage, and change the investment and reinvestment of the Digital Advice
Investor’s assets.
Clients and Digital Advice Investors are strongly encouraged to conduct their own analysis of, and
investigation into, the methodologies employed by SigFig and/or Financial Institutions. The fact
that a recommendation or guidance is generated by SigFig’s proprietary technology cannot be
interpreted as a guarantee of future performance. Investing in securities involves risk of loss that
Clients and Digital Advice Investors should be prepared to bear.
B. Risk Factors
Investing involves risk of loss, including (among other things) loss of principal, a reduction in
earnings (including interest, dividends, and other distributions), and the loss of future earnings.
The performance of any investment is subject to, and influenced by, multiple factors which include,
but are not limited to, inflation risk, market risk, interest rate risk, issuer risk, and general economic
risk. The discussion of material risks provided below is not meant to be a complete description of
risks that may be applicable to SigFig or its methods of analysis or investment strategies.
593719 (Rev 09 - 03/22) Page 12 of 28
Reliance on third-party information. SigFig conducts its analyses using detailed historical and
forward-looking information. SigFig relies on third parties, that may include certain Financial
Institutions, for the provision of market statistics, fund details, performance, and related
information and although these parties are generally reliable and reputable, there may be
inaccuracies or discrepancies in the information that is beyond SigFig’s control.
SigFig’s recommendations are based on the information and data filed by the issuers of securities
with various government regulators or made directly available to SigFig by such issuers, or
indirectly through other third-party sources. Although SigFig, through its proprietary software,
evaluates such information and data, SigFig is not in a position to confirm the completeness,
genuineness, or accuracy of such information and data, and in some cases, complete and
accurate information is not readily available.
SigFig bases its recommendations and/or guidance on information provided by Users, Clients, and
Digital Advice Investors and relies on Users, Clients, and Digital Advice Investors to provide
accurate information. If User, Client, or Digital Advice Investor provides inaccurate information, or
does not verify that SigFig’s portfolio tracker has accurately captured their portfolio holdings when
syncing with their account, this will impact the quality and relevance of SigFig’s recommendations
or guidance.
Market Risk. There is no guarantee that the securities selected by SigFig or the Financial
Institutions in the context of Digital Advice Program will achieve their objective. The securities
share price fluctuates and investors can lose money by investing in the securities. Securities may
differ from each other in terms of investment style, objectives, management, geographical
markets, holdings, and numerous other factors. For a full description of the risks inherent in any
specific security, Users, Clients, and Digital Advice Investors should read the prospectus of the
particular security recommended.
SigFig’s investment strategies and/or investments are likely to be exposed to risks relating to
weaknesses in various global economies and risks related to the economic cycle. Numerous
factors affecting the performance of SigFig’s investment strategies, such as market volatility,
interest rates, equity prices, currency prices, credit spreads, and deflationary and inflationary
pressures, may be affected by the economic cycle and long-term economic trends. Predictions
about financial market conditions and economic factors are highly uncertain, and the presence,
duration, and impact of any market or economic conditions could have a materially adverse effect
on SigFig’s investment strategies.
In recent years, disruptions in the global financial markets, the scope and severity of which are
without precedent in recent financial history, have had materially adverse consequences for the
values, liquidity, and stability of certain types of investments, including the types of investments
that SigFig’s clients may pursue. Similar or dissimilar disruptions may occur in the future, and the
duration, severity and ultimate effect of such disruptions are difficult to forecast. In the event of a
serious market disruption, SigFig may delay or suspend order submissions in respect of client
accounts. Such trading delays or suspensions may result in increased tracking error, lower returns
and/or an inability to effect portfolio strategies such as tax loss harvesting and rebalances.
Technology Risk. As mentioned above, SigFig provides its recommendations based on
proprietary software that utilizes various quantitative and qualitative models to generate
recommendations based on information input into the system by Clients and Digital Advice
Investors. Such computer-generated recommendations, like all investment recommendations,
may be subject to system error. No guarantee or representation is made that the investment
recommendations will be successful.

593719 (Rev 09 - 03/22) Page 13 of 28

 In addition, the operation of the software might be subject to human errors, processing or
communication errors or system failure. The changes made to the algorithms may not always
have the desired or intended effect. Further, as market dynamics (for example, due to changed
market conditions and participants) shift over time, a previously highly successful model may
become outdated or inaccurate, perhaps without the computer software system recognizing the
change before further recommendations are made. As such, Users, Clients and Digital Advice
Investors are urged to verify any recommendations generated by the SigFig software platform
with their own legal, financial, tax, and economic advisors and to conduct their own due diligence
on recommended investments before following any recommendation.
It is possible that Clients, Digital Advice Investors or SigFig itself may experience computer
equipment failure, loss of internet access, viruses or other events that may impair access to
SigFig's software-based investment advisory service. SigFig and its representatives are not
responsible to any Client or Digital Advice Investor for losses unless caused by SigFig's breach of
its fiduciary duty.
In making investment recommendations there are a number of factors that SigFig does not
consider, including but not limited to:
Transaction Costs and Frequency of Trading: With the exception of recommendations
specifically focused on the frequency of the Client’s or, if applicable, Digital Advice Investor’s
trading (e.g., a recommendation to trade less frequently), SigFig does not consider the frequency
of a Client’s or Digital Advice Investor’s trading when the proprietary software generates a
recommendation. If a Client’s or Digital Advice Investor’s investment approach involves a high
level of trading and turnover of their investments, such approach may generate substantial
transaction costs, tax implications (such as short-term capital gains) and other similar
consequences that could negatively impact the value of the investment portfolio. Clients and
Digital Advice Investors should bear these transaction costs in mind when deciding whether to
follow the recommendations generated by SigFig.
Certain Characteristics of Existing Portfolios: SigFig does not consider the restrictions that
may be inherent in a Client’s or Digital Advice Investor’s existing investment accounts when
making investment recommendations. For example, when making a recommendation to sell a
security and replace it with a similar security, SigFig does not consider (but attempts to disclose)
whether the existing security would be subjected to an early redemption fee if the Client or Digital
Advice Investor sells such security. Further, SigFig does not consider the brokerage costs for
effecting transactions in the Client’s or Digital Advice Investor’s existing investment accounts
when making securities recommendations. Clients and Digital Advice Investors should consider
such potential costs, if applicable, and consult their financial advisors, as necessary, before acting
on an investment recommendation made by SigFig.

593719 (Rev 09 - 03/22) Page 14 of 28

Tax Loss Harvesting: Clients or Digital Advice Investors should confer with their personal tax
advisor regarding the tax consequences of investing with SigFig and the Financial Institution and
engaging in the tax-loss harvesting strategy, based on their particular circumstances. Clients or
Digital Advice Investors, together with their personal tax advisors, are responsible for how the
transactions in their accounts are reported to the Internal Revenue Service (“IRS”) or any other
taxing authority. SigFig assumes no responsibility to Clients and Digital Advice Investors for the
tax consequences of any transaction, including any capital gains and/or wash sales that may
result from the tax-loss harvesting strategy. The performance of the new securities purchased
through for tax-loss harvesting purposes may have different expenses, returns, volatility and other
characteristics relative to the securities that are sold for tax-loss harvesting purposes. The
effectiveness of the tax-loss harvesting strategy to reduce tax liability will depend on the Client or
Digital Advice Investor’s entire tax and investment profile, including purchases and dispositions in
accounts (e.g., Client’s or Client’s spouse’s) outside of SigFig and the Financial Institution and
type of investments (e.g., taxable or nontaxable) or holding period (e.g., short-term or long-term).
The utilization of losses harvested through the strategy will depend upon the recognition of capital
gains in the same or a future tax period, and in addition may be subject to limitations under
applicable tax laws, e.g., if there are insufficient realized gains in the tax period, the use of
harvested losses may be limited to a $3,000 deduction against income and distributions. Losses
harvested through the strategy that are not utilized in the tax period when recognized (e.g.,
because of insufficient capital gains and/or significant loss carryforwards), generally may be
carried forward to offset future capital gains, if any.
SigFig only monitors for accounts managed by SigFig and the Financial Institutions. Clients and
Digital Advice Investors are responsible for monitoring their and their spouse’s accounts
managed by other investment advisers to ensure that transactions in the same security or a
substantially similar security does not create a “wash sale.” A wash sale is the sale at a loss and
purchase of the same security or substantially similar security within 30 days of each other. If a
wash sale transaction occurs, IRS may disallow or defer the loss for current tax reporting
purposes. More specifically, the wash sale period for any sale at a loss consists of 61 calendar
days: the day of the sale, the 30 days before the sale, and the 30 days after the sale. The wash
sale rule postpones losses on a sale, if replacement shares are bought around the same time.
SigFig may lack visibility to certain wash sales, should they occur as a result of external accounts,
and therefore SigFig may not be able to affect whether a loss is successfully harvested and, if so,
whether that loss is usable by the Client or Digital Advice Investor in the most efficient manner.
In order to avoid wash sales due to one or more transactions in the Client or Digital Advice
Investor’s account, from time-to-time SigFig might replace a recommended investment (“primary”
ETF) with a “similar” investment (“secondary” ETF) as part of the tax-loss harvesting strategy
which may not be commission free. The secondary ETF is expected, but is not guaranteed to,
perform similarly and that might lower a Client or Digital Advice Investor’s tax bill while
maintaining a similar expected risk and return on the portfolio. Expected returns and risk
characteristics are no guarantee of actual performance.

593719 (Rev 09 - 03/22) Page 15 of 28

 C. Material Risks of Investing in Mutual Funds and ETFs
Exchange-Traded Funds ("ETFs"). An ETF generally is an investment company, unit
investment trust or a portfolio of securities deposited with a depository in exchange for depository
receipts. The portfolios of ETFs generally consist of common stocks that closely track the
performance and dividend yield of specific securities indices, either broad market, sector or
international. Fixed income ETFs generally consist of bonds issues by corporations or
government. ETFs provide investors the opportunity to buy or sell throughout the day an entire
portfolio of stocks in a single security. Although index mutual funds are similar, their shares are
generally issued and redeemed only once per day at market close. Investment in an ETF involves
payment of such company’s pro rata share of administrative fees charged by such company, in
addition to those paid by a Client or Digital Advice Investor. Supply and demand in the market for
either the ETF and/or the securities held by the ETF may cause the ETF shares to trade at a
premium or discount to the actual net asset value of the securities owned by the ETF.
Mutual Funds. An investment in mutual funds could lose money over short or even long periods.
Clients and Digital Advice Investors should expect the fund’s share price and total return to
fluctuate within a wide range, like the fluctuations of the overall stock market.
An ETF’s or mutual fund’s performance could be impacted by a number of factors including but not
limited to:
Investment style risk: the chance that returns from small and mid-capitalization growth stocks will
trail returns from the overall stock market. Historically, small and mid-cap stocks have been more
volatile in price than the large-cap stocks that dominate the overall market, and they often perform
quite differently. Small and mid-size companies tend to have greater stock volatility because, among
other things, these companies are more sensitive to changing economic conditions.
Market risk: the chance that stock prices overall will decline.
Manager risk: the chance that an ETF or a mutual fund manager may make a poor security selection
or focus on securities in a particular sector, category, or group of companies will cause the mutual
fund to underperform relevant benchmarks or other funds with a similar investment objective.
Interest rate risk: the chance that bond prices will decline because of rising interest rates. Interest
rate risk should be moderate for the Fund because it invests primarily in short- and intermediate-term
bonds, whose prices are less sensitive to interest rate changes than are the prices of long-term
bonds.
D. Operating Events
Trade errors and other operational mistakes (“Operating Events”) occasionally occur in connection
with the servicing and management of Clients and Digital Advice Investors’ accounts (“Portfolios”).
SigFig maintains policies and procedures that address identification and correction of Operating
Events, consistent with applicable standards of care and client documentation. An Operating
Event generally is compensable by SigFig to a Client or Digital Advice Investor when it is a
mistake (whether an action or inaction) in which SigFig has, in its reasonable view, deviated from
the applicable investment guidelines or the applicable standard of care in managing a Portfolio,
subject to the considerations set forth below.

593719 (Rev 09 - 03/22) Page 16 of 28

Compensable Operating Events may include, but are not limited to: (i) the placement of orders
(either purchases or sales) in excess of the amount of securities intended to trade for a Portfolio;
(ii) the purchase (or sale) of a security when it should have been sold (or purchased);
(iii) the purchase or sale of a security not intended for the Portfolio; (iv) the purchase or sale of a
security contrary to applicable investment guidelines or restrictions; and (v) incorrect allocation of
trades. SigFig makes its determinations regarding Operating Events pursuant to its policies on a
case-by-case basis, in its discretion, based on factors it considers reasonable, including
regulatory requirements, contractual obligations, and business practices. Not all Operating Events
will be considered compensable mistakes. Relevant factors SigFig considers when evaluating
whether an Operating Event is compensable include, among others, the nature of the service
being provided at the time of the event, specific applicable contractual and legal requirements and
standards of care, whether an applicable investment objective or guideline was contravened, the
nature of the client’s investment program, and the nature of the relevant circumstances.
Operating Events may result in gains or losses or could have no financial impact. Where SigFig’s
actions or inactions resulted in an Operating Event impacting a Digital Advice Investor’s account,
the Operating Event is reported to the Financial Institution and the account impacted is generally
corrected in accordance with procedures established by the Financial Institution. With respect to
an Operating Event which impacted a Client account, the Client is made whole from any losses
and retains any gain resulting from the Operating Event.

593719 (Rev 09 - 03/22) Page 17 of 28

 ITEM 9

DISCIPLINARY INFORMATION
Neither SigFig nor any of its employees have had any administrative proceedings before the SEC,
any other federal regulatory agency, any state regulatory agency, or any foreign financial
regulatory authority. Neither SigFig, nor any of its employees, has had any proceedings before a
self-regulatory organization. The Digital Advice Investors should refer to the relevant Financial
Institution’s Brochure for the disciplinary information on such Financial Institution.

593719 (Rev 09 - 03/22) Page 18 of 28

ITEM 10

OTHER FINANCIAL INDUSTRY ACTIVITIES

AND AFFILIATIONS
A. No Broker-Dealer Affiliations
Neither SigFig, nor any of its supervised persons are registered, or have an application pending to
register as a broker-dealer or a registered representative of a broker-dealer.

B. No Affiliations with Futures Commission Merchants, Commodity Pool

Operators, or Commodity Trading Advisor
Neither SigFig, nor any of its supervised persons are registered, or have an application pending to
register as a Futures Commission Merchants, Commodity Pool Operators or Commodity Trading
Advisor or an associated person of the forgoing entities.

C. Relationships Material to SigFig's Business

Some model asset allocations offered by SigFig are supplied by and are proprietary to third-party
investment advisers not affiliated with SigFig. Certain model asset allocations offered through
SigFig's partnerships with the Financial Institutions may also be supplied by third-party advisers
not affiliated with SigFig. This gives rise to a conflict of interest in those instances, as the third
parties are incentivized to recommend these models and the investment products in them through
SigFig’s or Digital Advice platform.

Neither SigFig, nor any of its supervised persons, have a relationship or arrangement with a
related person that is material to its advisory business or to its Clients.

As noted in Item 4, SigFig's Partners may be investment advisors, brokers, futures commission
merchants, commodity pool operators, or commodity trading advisors. Digital Advice Investors are
encouraged to review the relevant Financial Institution’s Brochure as such institutions might have
financial industry affiliations.

593719 (Rev 09 - 03/22) Page 19 of 28

 ITEM 11

CODE OF ETHICS, PARTICIPATION OR

INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
A. SigFig’s Code of Ethics
SigFig has adopted a Code of Ethics (the “Code”), which is designed to meet the requirements of
Rule 204A-1 of the Investment Advisers Act of 1940 (the “Advisers Act”). The Code applies to
SigFig’s “Access Persons.” Access Persons include, generally, any officer or director of SigFig
and any employee or other supervised person of SigFig (including certain contractors) who, in
relation to the Clients and Digital Advice Investors, (1) has access to non-public information
regarding any purchase or sale of securities; or (2) is involved in making securities
recommendations or (3) has access to such recommendations that are non-public.

The Code sets forth a standard of business conduct that takes into account SigFig’s status as a
fiduciary and requires Access Persons to place the interests of the Clients and Digital Advice
Investors above their own interests. The Code requires Access Persons to comply with applicable
federal securities laws. Further, Access Persons are required to promptly bring violations of the
Code to the attention of SigFig’s Chief Compliance Officer. All Access Persons are provided with
a copy of the Code and are required to acknowledge receipt of the Code on at least an annual
basis and any time material amendments are made.

As required by Rule 204A-1 of the Advisers Act, SigFig’s Access Persons must provide SigFig
with a list of their personal accounts and an initial holdings report within 10 days of becoming an
Access Person. SigFig also requires its Access Persons to report their securities transactions on
a quarterly basis thereafter and disclose their securities holdings on an annual basis. SigFig
restricts the personal trading of its Access Persons as reflected in the Code of Ethics.

The Code also includes insider trading policies and procedures that are designed to prevent the
improper use of material, non-public information. Such insider trading policies and procedures
prohibit SigFig and its personnel from trading for their personal account, or recommend trading in,
any securities while in possession of material, non-public information about such security, and
from disclosing such information to any person not entitled to receive it.

A copy of SigFig’s Code of Ethics can be obtained by contacting the Chief Compliance Officer at
legal@SigFig.com.

B. Securities Recommendations
Neither SigFig, nor any of its related persons, recommends to Clients or Digital Advice Investors,
or buys or sells for their accounts, securities in which SigFig has a direct material financial
interest.

SigFig does have investment authority to purchase or sell securities on behalf of Clients and
Digital Advice Investors. However, SigFig’s Access Persons may purchase securities for their own
accounts which may, in certain instances, be the same securities as those recommended to
Clients or purchased on behalf of Digital Advice Investors.

593719 (Rev 09 - 03/22) Page 20 of 28

The Code of Ethics requires Access Persons to place the interests of Clients and Digital Advice
Investors over their own or those of SigFig, and all Access Persons are required to acknowledge
their receipt and understanding of the Code.

C. Securities Transactions of SigFig and its Related Persons

As stated above, SigFig does not buy securities for its own account so no conflict exists at the
firm level.

With certain exceptions specified in the Code, Access Persons may generally invest in securities
that are also owned by Clients or Digital Advice Investors, which may be a conflict of interest as
such Access Persons may be inclined to transact in the securities based on their own interests
and advanced knowledge of pending orders, rather than the interests of the Clients and Digital
Advice Investors. Currently, only a limited number of Access Persons of SigFig have access to the
information on the timing of the trades execution for Clients’ and Digital Advice Investors’
accounts. The Code of Ethics generally prohibits such Access Persons from trading in the
securities that are owned by Clients and Digital Advice Investors.

Additionally, certain Access Persons may become Clients or Digital Advice Investors and to the
extent they are, they will receive recommendations at the same time as similarly situated Clients
and Digital Advice Investors. Because SigFig’s recommendations are based on an objective
ranking engine, there is no conflict of interest and Clients or Digital Advice Investors will not be
prejudiced.

As mentioned above, SigFig’s Code of Ethics also contains policies and procedures prohibiting
insider trading that are designed to prevent the misuse of material, non-public information. SigFig
personnel are required to certify their compliance with the Code.

D. Recommending Securities to Clients

As mentioned in Item 11.C, SigFig does not buy securities for its own account. Therefore, no
potential conflict of interest exists at the firm level. Access Persons may desire to trade securities
that the firm is trading for Clients or Digital Advice Investors, that may lead to a conflict of interest
discussed in Item 11.C. As noted in Item 11.C, SigFig’s Code of Ethics generally prohibits Access
Persons who have knowledge on the timing of the trades execution for Clients’ and Digital Advice
Investors’ accounts.

593719 (Rev 09 - 03/22) Page 21 of 28

 ITEM 12

BROKERAGE PRACTICES
SigFig determines the broker-dealer to be used and the commission rates to be paid in Client
accounts. SigFig requires that all trade orders for securities transactions for Client accounts are
placed with Charles Schwab & Co., Inc., Fidelity Brokerage Services LLC and/or TD Ameritrade,
Inc. For the Digital Advice Program, SigFig is directed to use broker-dealers designated by the
Financial Institution, subject to best execution. SigFig seeks to ensure that the brokers executing
trades for its Clients and Digital Advice Investors (“Approved Brokers”) receive the best overall
execution for securities transactions by continuing to monitor and review the best execution
capability of the Approved Brokers. When assessing the best execution capability of the Approved
Brokers, SigFig will consider the following factors: speed and quality of trade execution, frequency
and amount of price improvement on trade and overall execution quality among other factors.
Clients may pay a commission on transactions in excess of the amount of commission another
broker-dealer would have charged, but SigFig considers the trading commissions as well as
general operational support and service provided to determine reasonableness of compensation
of the Approved Brokers.

SigFig's Clients pursue one or more different investment strategies and objectives. At times a
particular investment may be deemed suitable for one Client but not another, or may be deemed
potentially suitable for a range of Client accounts. When SigFig has deemed an investment
suitable for more than one account, in order to achieve efficient execution, SigFig often
aggregates orders for groups of Client accounts in order to trade blocks of securities. When block
trading is utilized, all participating accounts are allocated the same average price for the security.
As a result, the price may be either more or less favorable to the Client than it would be if similar
transactions were not being executed concurrently for other Accounts. Trades that cannot be
aggregated and traded in a block are submitted in a randomized process seeking to ensure that
each Client generally has equal priority over time. By not aggregating transaction orders and
trading at different times during the day, Clients may potentially pay higher prices when buying
securities, or receive lower prices when selling securities compared to the other accounts
depending on the size of the trades and the liquidity of the securities.

As noted elsewhere in this Brochure, recommendations made by SigFig and Financial Institution
in the context of the Digital Advice Program, will, in certain cases, be executed by broker-dealers
affiliated with the Financial Institution. In other cases, a broker-dealer affiliated with the Financial
Institution will act as an introducing broker-dealer, while another broker selected by the Financial
Institution will act as a clearing broker. As such, at times the trade execution is directed to an
affiliated or otherwise selected broker-dealer, Digital Advice Investors may not obtain rates as low
as they might otherwise obtain if a different broker-dealer is used. Also, such arrangements may
cause the affiliated broker-dealer to earn additional compensation (such as clearing and custody
payments). Please review the relevant Financial Institution’s Brochure for more information.

SigFig does not currently receive research and services from broker-dealers as a part of
commission rates paid to broker-dealers. SigFig will update this Brochure if it does receive
research and services from broker-dealers and any such research or services would be in
compliance with Section 28(e) of the Securities Act of 1934.

593719 (Rev 09 - 03/22) Page 22 of 28

ITEM 13

REVIEW OF ACCOUNTS
A. Periodic Review of Client Accounts
SigFig's Portfolio Management Team frequently reviews the accounts of Clients and Digital
Advice Investors and utilizes the algorithms to periodically rebalance each portfolio with a goal to
maintain the Client’s or Digital Advice Investor’s risk profile and the recommended asset
allocation. In the context of the Digital Advice Program, the relevant Financial Institution may
establish its own oversight program to monitor the Digital Advice Investors’ accounts.

SigFig provides Clients and Digital Advice Investors with continuous access via the online client
portals where they can access their account documents and information. On an annual basis,
SigFig contacts Clients on its own behalf and Digital Advice Investors on behalf of the relevant
Financial Institution to review and update the previously provided answers to the risk profile
questionnaire. Clients and Digital Advice Investors may also receive periodic email
communications describing portfolio performance, account information and reminders to review
their personal risk profile previously provided.

Users without investment management accounts utilize SigFig’s free portfolio tracking services to
view and review their synced or manually inputted account data and receive guidance. SigFig has
no discretion over User accounts and will only provide guidance to Users based on Data provided
by such User.

Users, Clients and Digital Advice Investors are strongly encouraged to conduct their own analysis
of, and investigation into, the methodologies employed by SigFig in making its recommendations.
The fact that a recommendation is generated by SigFig cannot be interpreted as a guarantee of
future performance. Investing in securities involves risk of loss.

B. Reports Given to Clients

In addition to the account statements that the Clients receive from their custodians, SigFig sends
periodic account summary emails to its Users and Clients, which periodic reports include
information regarding the User’s or Client’s portfolio, including performance, top movers (up and
down) and performance versus a relevant index. The reports also include top news stories.

SigFig also sends other periodic or event inspired reports based upon market or portfolio activity.
In addition, when Users or Clients log in to their SigFig account, they can view their portfolio
performance, asset allocation, dividends, key statistics and portfolio ratios, and geographic
allocation data, among other information. Clients are encouraged to compare any reports they
received directly from SigFig with the account statements they receive from their custodian.

With respect to the Digital Advice Program, SigFig coordinates with the relevant Financial
Institution to provide relevant summary emails to Digital Advice Investors. In most cases, the
custodian of the Digital Advice Program accounts will provide Digital Advice Investors with
periodic account statements showing their securities positions and account activity.

593719 (Rev 09 - 03/22) Page 23 of 28

 ITEM 14

CLIENT REFERRALS AND COMPENSATION

SigFig maintains a referral relationship with Cambridge Savings Bank ("CSB") under which CSB
may refer its current or prospective banking customers to SigFig for the provision of discretionary
investment advisory services as outlined in Item 4.B(1) in return for compensation paid to CSB by
SigFig. CSB’s unlicensed personnel in certain CSB branches may also receive a nominal fee paid
by CSB for the qualified Client referrals. Under the terms of the referral agreement between CSB
and SigFig, CSB must provide to the referred Clients a standard written solicitor’s disclosure
document and this Form ADV Part 2A consistent with Rule 206(4)-3 under the Investment
Advisers Act, as amended. SigFig referral arrangement with CSB does not constitute a Digital
Advice Program as described elsewhere in this Brochure.

To the extent SigFig does enter into any other arrangements, all such compensation will be fully
disclosed to Clients and/or Digital Advice Investors, as applicable, consistent with applicable law
and to the extent necessary will be conducted in accordance with SEC Rule 206(4)-1 under the
Advisers Act, as well as relevant guidance.

593719 (Rev 09 - 03/22) Page 24 of 28

ITEM 15

CUSTODY
SigFig is deemed to have constructive custody of Client assets because SigFig maintains the
username and password for its Clients. Although SigFig has robust procedures to prevent any
unauthorized access of a Client’s account, SigFig will also perform the verification procedures for
such accounts and will be subject to an additional surprise audit required under Rule 206(4)-2 of
the Advisers Act.

SigFig will ensure that the Client funds and securities for which it has constructive custody are
physically maintained with a "qualified custodian" in a separate account for each Client under the
Client’s name. Clients will receive quarterly, or more frequent, account statements directly from
their custodian. At this time, it is not anticipated that SigFig will open accounts with qualified
custodians on behalf of clients.

With respect to the Digital Advice Programs offered through partnerships, SigFig is deemed to
have constructive custody of Digital Advice Investors’ assets in the event SigFig maintains such
Digital Advice Investor’s username and password. SigFig generally does not have custody over
the Digital Advice Program accounts. The Financial Institutions, their affiliate(s), or a third-party
custodian of the Financial Institution’s choosing will maintain custody of the securities and cash
comprising each account. Digital Advice Investors will receive quarterly, or more frequent, account
statements directly from their respective custodian.

Clients and Digital Advice Investors should carefully review the statements sent by the qualified
custodians and are urged to compare accounts summary emails sent by SigFig or the relevant
Financial Institution (or provided via the Website) to the account statements received from the
qualified custodians.

593719 (Rev 09 - 03/22) Page 25 of 28

 ITEM 16

INVESTMENT DISCRETION
SigFig has broad discretion, subject to restrictions imposed by the Client and limitations in the
Client’s Investment Advisory Agreement, to determine the securities to be bought or sold, amount
of securities to be bought or sold, broker-dealer to be used for a purchase or sale of securities,
and commission rates to be paid to a broker-dealer in a Client’s accounts.

SigFig does not have discretionary authority over any external brokerage accounts synced onto
its online platform by the Users.

With respect to the Digital Advice Programs, SigFig will manage the Digital Advice Investor’s
accounts in accordance with the investment portfolios approved by the Financial Institution or will
implement and manage the investment recommendations as provided to SigFig by the Financial
Institution.

As noted above, Clients and Digital Advice Investors may impose reasonable restrictions, subject
to review and approval by SigFig and, in the case of Digital Advice Program, the Financial
Institution. Prior to assuming discretionary authority, the Financial Institution, with respect to
Digital Advice Investors, or SigFig, with respect to Clients, receives a limited power of attorney
from the respective investor.

593719 (Rev 09 - 03/22) Page 26 of 28

ITEM 17

VOTING CLIENT SECURITIES

SigFig does not vote proxies on behalf of the Clients or Digital Advice Investors. SigFig does not
have the authority to vote Client or Digital Advice Investors securities.

593719 (Rev 09 - 03/22) Page 27 of 28

 ITEM 18

FINANCIAL INFORMATION
SigFig is not currently aware of any financial condition that is reasonably likely to impair its ability
to meet contractual commitments to its Clients or Digital Advice Investors.

593719 (Rev 09 - 03/22) Page 28 of 28

We Respect Your Privacy
Before you dig through the legalese, we would like to make one thing very clear: We
will never rent or sell your personal information. Without trust, we will not have any
users, and without users... well, we are out of a job.
Looking for something specific but don't want to dig through the legalese?
Email us at privacy@sigfig.com.
Last updated December, 2021
Nvest, Inc. (dba SigFig) and its affiliates and subsidiaries, including SigFig Wealth Management
LLC ("we", "us" or “SigFig”), are committed to protecting and respecting your privacy. This privacy
policy ("Privacy Policy") sets out our policies and procedures for collecting, using, maintaining,
protecting and disclosing information provided to us by you when you access or browse
SigFig.com, other Nvest, Inc. owned and/or operated websites, and our portfolio tracking services
on our partner sites (the "Partner Portfolio Trackers") (collectively, the "Sites").
This Privacy Policy describes the type of information that we may collect for our own purposes
through the Sites, how we use, protect, and share that information, and the choices and rights that
you have. In some circumstances, we may receive or process personal information on behalf of a
client for whom we serve as a service provider. This Privacy Policy does not describe all the
information we may collect on behalf of or receive from our clients as a service provider. It also
does not describe how we use, protect, or share that information. In those situations, the privacy
policy of the client will apply.
This Privacy Policy applies to information we collect:
• On our Sites.
• In email, text and other electronic messages between you and us that are related to
the services that we are providing you.
• Through our mobile and desktop applications, which provide dedicated non-browser-based
interaction between you and our Sites.
Please read this Privacy Policy carefully to understand our policies and practices regarding your
information and how we will treat it. This Privacy Policy governs your use of our services and by
accessing or using our Sites you agree to this Privacy Policy and you consent to the collection,
transfer, processing, storage, disclosure and other uses described in this Privacy Policy. If you do
not agree with our policies and practices, your choice is to not use our Sites. For purposes of
compliance with the Gramm-Leach-Bliley Act (the "GLB Act"), this Privacy Policy shall serve as
both your initial and annual “privacy notice” as defined under the GLB Act.
If you have any questions or concerns regarding this statement, you should contact us at
privacy@sigfig.com.

593719 (Rev 09 - 03/22) Page 1a

Information Collected by Us
We collect user-submitted information by which you may be personally identified, such as name,
email address, and by which you may be contacted online or offline with notifications related to the
use of the services offered by the Sites and other information you may provide, such as your age,
income, liquid assets worth and risk tolerance. We maintain information you submit in your profile
on the Sites. We collect information from you when you send us feedback as well. Some
information collected is not explicitly submitted by the user. Examples of such information include
(but are not limited to): browser-type related information, IP address, requested URL, referring URL,
and timestamp. See "Use of Cookies and IP Address" below. If you choose to use our portfolio
tracker service, we also collect your external brokerage account login credentials provided by you
and information about your holdings in those accounts for the purpose of providing the services.
In addition, we may collect information provided by users who chose to open an investment advisory
account with us, including (but are not limited to):
• Social Security numbers and financial account numbers;
• Account balances and transaction information;
• Income and Employment Information;
• Birthdate;
• Physical Address;
• Email Address;
• Marital Status;
• State or Federally-Issued Identification (Driver’s License/Passport);
• Information about your beneficiaries;
• Salary; and
• Contact Information.
(Collectively, “personal information”).
Also, if you sync your brokerage account(s) and/or bank account(s) to our Sites, your financial
institution may provide us with information about you and your account to facilitate our ability to
provide our services to you and to reduce the amount of data you need to enter.
We keep records of our services, which may include but are not limited to, records of the advice that
we provide to you, your use of our services, and your communications to us about our services.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal
information:
• To present our Sites and its contents to you;
• To provide you with information, products or services that you request from us;
• To market, personalize, develop and improve our products and services;
• To fulfill any other purpose for which you provide it;
• To carry out our obligations and enforce our rights arising from any contracts entered into
between you and us, including for billing and collection;
593719 (Rev 09 - 03/22) Page 2a
 • To notify you about changes to our Sites or any products or services we offer or provide
through our Sites;
• To respond to your feedback or inquiries;
• In any other way we may describe when you provide the information; and
• For any other purposes with your consent.
Your personal and investment information is maintained by us in order to provide you with customized
investment and other services and to fulfill our legal and regulatory requirements. In addition, for users
who elected to open a SigFig investment advisory account, we use the collected information to:
• Facilitate opening an account with an independent brokerage and custodial firm (“Broker-
Dealer”);
• Creating, implementing, and continuously managing your investment portfolio strategy aligned
with the investment preferences specified by you;
• Provide the Broker-Dealer with ongoing information required to provide ongoing wealth
management services to you;
• Provide you with notifications related to your investment advisory account and our wealth
management services.
Data that does not include personal information may be used for research purposes. For instance,
we may compile data, excluding personal information and aggregated, for purposes of
demographic analysis and research.

Service-related Announcements
We will send you service-related announcements on the rare occasions when it is necessary to
do so. For instance, if our service is temporarily suspended for maintenance, we might send you
an email. Generally, you may not opt-out of these communications, which are not promotional in
nature. If you do not wish to receive them, you have the option to deactivate your account.

Use of Cookies and IP Addresses

As you navigate through and interact with our Sites, we may use automatic data collection
technologies to collect certain information about your equipment, browsing actions and patterns,
including browser-type related information, IP address, requested URL, referring URL, timestamp
data, and other information help us diagnose problems with our servers, administer the Sites, and
otherwise provide the highest possible level of service to you. In addition, we use this non-
personal information to perform statistical analyses of user behavior and characteristics in order to
measure interest in and use of the various areas of the site.
Like most websites, the Sites require cookies to function properly. Cookies are small text files that
reside on a user's computer and identify you as a unique user. We use cookies to refine our
services and simplify the user experience. For example, the use of cookies allows registered
users to enter our Sites without explicitly typing in their email address and password every time,
and it allows us to personalize your experience on the Sites by, e.g., showing you your account
balances. For these reasons we tie personal information such as your email address to our
cookies. If you do not want information collected through the use of cookies, there is a simple
procedure in most browsers that allows you to deny or accept the cookie feature; however, you
should note that cookies might be necessary to provide you certain features (e.g., customized
delivery of information) available on the Sites.

593719 (Rev 09 - 03/22) Page 3a

We use tracking utility companies that uses cookies and Web beacons on our Sites. We have no
access to or control over these third party tracking utilities. For example, we use cookies in
conjunction with Google Analytics Demographics and Interest Reporting in order to better
understand our visitors. Google Analytics collects information such as how often users visit our
Sites, what pages they visit when they do so, and what other sites they used prior to coming to our
Sites. We use the information we get from Google Analytics only to maintain and improve our
Sites. Google Analytics does not collect your name or other identifying information. We do not
combine the information collected through the use of Google Analytics with personal information.
Although Google Analytics plants a permanent cookie on your web browser to identify you as a
unique user the next time you visit our Sites, the cookie cannot be used by anyone but Google.
Google’s ability to use and share information collected by Google Analytics about your visits to
our Sites are restricted by the Google Analytics Terms of Use and the Google Privacy Policy. As
related to Google Analytics, visitors can choose to opt out using Ads Settings, Ad Settings for
mobile apps, or any other available means including Google Analytics' opt out tool. Unlike Google
Analytics, not all tracking utility companies allow users to opt-out. If you do disagree with our use
of cookies as set forth in this section, your choice is to not use our Sites.

Partner Sites and Advertising

If you use the Partner Portfolio Trackers, we may share certain information about you with our
partners, such as "top ticker" data and watchlist holdings, which allow the partners to personalize
your experience on the site or their mobile apps. We may also share aggregate data with partners
(without any of your personal information) to aid in monitoring the effectiveness of our product.
Such data could include engagement and retention rates with our services, periodic usage
metrics reports.
Unless we have your express permission, we will not share any personal information about you
with any advertising companies or with the providers of the advertised goods and services, and
these companies will not collect such information on our behalf. If you choose to use these
separate goods and services, disclose information to the providers, or grant them permission to
collection information about you, then their use of your information is governed by their privacy
policies.

Disclosure/Transfer of Information
Some of the information you provide on our Sites is publicly exposed in an aggregated and/or
anonymized manner unless otherwise noted. However, except as set forth in this Privacy Policy,
we do not sell, rent, share, trade, or give away any of your personal information. We do not share
your personal information for a third parties’ promotional use without your express consent. We
may disclose personal information that we collect or you provide as described in this Privacy
Policy:
• To our subsidiaries and affiliates;
• To contractors, service providers and other third parties we use to support our business and
who are bound by contractual obligations to keep personal information confidential and use it
only for the purposes for which we disclose it to them;
• We will disclose information about individual users to governmental or judicial authorities or
law enforcement agencies, or to other individuals or entities, in response to subpoenas, court
orders, or other legal processes. Further, we may share information in order to investigate,
prevent, or take action regarding illegal activities or suspected fraud, or to enforce or apply the
terms and conditions of this Privacy Policy;
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 • To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• With your consent;
• To enforce or apply our Terms of Use; and
• If we believe disclosure is necessary or appropriate to protect our rights, property, or safety or
the rights, property or safety of our customers or others.
We reserve the right to transfer your personal information in the event of a transfer of our
ownership, such as a restructuring, an acquisition by or merger with another company. In such an
event, we will notify you before information about you is transferred and becomes subject to a
different privacy policy. For the users who chose to open an investment advisory account with us,
the transfer of personal information in the event of a transfer of our ownership is governed by the
Investment Advisory Agreement between us and such users.
We will notify you when information about you may be provided to third parties in ways other than
explained above, and you will have the option to prevent such information sharing.

Security
We have implemented measures designed to secure your personal information from accidental
loss and from unauthorized access, use, alteration, and disclosure. Our security measures
include industry standard technology and equipment to help protect your personal information.
The safety and security of your information also depends on you. Where we have given you (or
where you have chosen) a password for access to certain parts of our Sites, you are responsible
for keeping this password confidential. We ask you to not share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although
we take appropriate measures to safeguard against unauthorized disclosures of information, we
cannot guarantee the security of your personal information transmitted to our Sites. Any
transmission of personal information is at your own risk.
You hereby acknowledge that we are not responsible for any intercepted information sent via the
Internet or the circumvention of any privacy settings or security measures contained on our Sites,
and you hereby release us from any and all claims arising out of or related to such interceptions
of information or circumventions of our Sites.

Customer Preferences and Opt-out Choices

We may also use your information to contact you about our services that may be of interest to
you. If you do not want us to use your information in this way, please provide notice to us through
one of the following ways:
• Adjust your user preferences in your account profile; or
• To opt-out of receiving promotional or marketing communications from us at a specific
address, you may:
○ Use the unsubscribe instructions sent by us.
○ Or Contact us by mail at:
Nvest, Inc.
2443 Fillmore Street, #380-1512
San Francisco, CA 94115

593719 (Rev 09 - 03/22) Page 5a

 ○ Note: It may take up to ten (10) business days to process your request post receipt of the
request.

Accessing/Updating/Deleting Personal Information

Should you want to update your personal information, or to request assistance with accessing,
correcting, or deleting any personal information included in your account, please email
support@sigfig.com. We will respond to your request promptly, but no later than within thirty
(30) days of receipt of such request. We may not accommodate a request to change information if
we believe the change would violate any law or legal requirement or cause the information to be
incorrect. We cannot delete individual personal information for you, but can do a wipe of all of a
user's personal information upon request. Please note, however, that even if we close your
account, we may retain and use your information as necessary to comply with our legal and
regulatory obligations, resolve disputes, and enforce our agreements. Please also note that there
might be latency in deleting information from our servers and backed-up versions might exist after
deletion.

Respecting Children's Privacy

Our Sites are not directed to children, and we do not knowingly solicit information from any child
under the age of 13. If you are under the age of 13, do not use or provide any information on our
Sites or on or through any of its features or provide any information about yourself to us, including
your name, address, telephone number, email address, or any screen name or user name you
may use. If a parent or guardian becomes aware that his or her child has provided us with
personal information without his or her consent, he or she should contact us at
privacy@sigfig.com. Should a child whom we know to be under 13 send personal information to
us, we will delete it as soon as possible.

Your Privacy Rights

In certain circumstances you may have the following rights in relation to the processing of your
personal information:
• Access Request
To request a copy of the personal information we process in relation to you including (i) the
categories of personal information we collected about you and the categories of sources from
which we collected the personal information; (ii) the business or commercial purpose for
collecting the personal information about you (iii) the categories of third parties to whom we
disclosed personal information and the categories of personal information disclosed; and (iv)
the specific pieces of personal information we collected about you.
• Deletion Request
To ask that we delete personal information that we process in relation to you where we do not
have a legal or regulatory obligation or other valid reason to continue to process it.
• Objection Request
To object to the processing of your personal information if (i) we are processing your
personal information on the grounds of legitimate interests or for the performance of a task
in the public interest (including profiling); or (ii) if we are processing your personal
information for direct marketing purposes.

593719 (Rev 09 - 03/22) Page 6a

 • Correction Request
To request that we update the personal information we process in relation to you, or to
correct personal information that you think is incorrect or incomplete.
You may exercise your rights at any time by using the details set out in the Contact section, To
the extent permitted by applicable law or regulation we reserve the right to charge an appropriate
fee in connection with you exercising your rights.
We may need to request specific information from you to help us confirm your identify and ensure
your right to access to the personal information requested, or to exercise any of your other rights.
This is to ensure that personal information is not disclosed to any person who does not have
authority to receive it. We may also request further information in relation to your request to help
us locate the personal information processed in relation to you, including, for example, the nature
and location of your relationship with us.
We aim to respond to all legitimate requests within thirty (30) days of receipt of such requests. If
we think it may take us longer (such as where your request is particularly complex or you have
made a number of requests), we will notify you and keep you updated.
You will not be disadvantaged in any way by exercising your rights in relation to the processing of
your personal information.

Links
Our Sites may contain links to third party websites to which we have no affiliation. The links are
provided on our Sites solely for your convenience and may assist you in locating other useful
information on the Internet. Unless you expressly authorize us to do so, we will not share your
personal information with such third party websites. These third party websites are not under our
control. In using such third party websites please be aware that each third party website is subject
to its own privacy policies and is not covered by our Privacy Policy. We make no representation or
warranty regarding the accuracy of the information contained on such third party websites, and
we disclaim all responsibility relating to or resulting from your use of such third party websites.

Frames and Partner Sites

Our Sites utilize framing techniques to allow users to access content from our Sites, when the
user is actually on a third party website. We do this so that you will have a more seamless
experience on the third party site. Regardless of our framing techniques, the third party and its
website will remain visible and fully accessible, and will be governed by the privacy policy of the
third party site, which will appear on those pages.
Conversely, the Partner Portfolio Trackers appear on our partners' websites but are actually
offered or hosted by us. The Partner Portfolio Trackers will be clearly marked with our name, and
your use of them will be governed by this Privacy Policy.

Modifications to the Privacy Policy

This Privacy Policy may change from time to time. If we make a change to this Privacy Policy that
we believe materially reduces your rights, we will provide you with prominent notice on our Site’s
home page. By continuing to use our services after those changes have become effective, you
agree to be bound by the revised Privacy Policy. The date this Privacy Policy was last revised is
identified at the top of the page. You are responsible for periodically visiting our Sites and this
Privacy Policy to check for any changes.

593719 (Rev 09 - 03/22) Page 7a

Contact
If you have questions, comments, concerns or feedback regarding this Privacy Policy or any other
privacy or security concern, please send an email to privacy@sigfig.com.
Nvest, Inc.
2443 Fillmore Street, #380-1512
San Francisco, CA 94115
Phone: (855)-9SIGFIG

593719 (Rev 09 - 03/22) Page 8a