Solicitor’s Disclosure

This disclosure is being provided to you in accordance with Rule 206(4)-3 under the Investment Advisers Act of 1940, as amended (“Advisers Act”).

Society for Human Resource Management (“SHRM”) has entered into an agreement with Raymond James Financial Services Advisors, Inc. (“RJFSA”) and Raymond James & Associates, Inc. (“RJA”) (collectively, “Raymond James”) pursuant to which SHRM refers its members to Raymond James for investment advisory services in exchange for compensation paid to SHRM by Raymond James.

Under the arrangement, Raymond James pays SHRM a referral fee equal to a percentage of the investment advisory fees received by Raymond James from business organizations that are SHRM members referred to Raymond James by SHRM who become advisory clients of Raymond James through Chip Morton, an investment adviser representative (“IAR”) of RJFSA, Kevin Mahoney, an IAR of RJA, or other IARs of Raymond James operating under the trade name “Corporate Advisers Group” (collectively, the “CAG Team”).

RJFSA and RJA are each investment advisers separately registered under the Advisers Act with the U.S. Securities and Exchange Commission. IARs provide advisory services as representatives of RJA or RJFSA. Corporate Advisors Group is not a separately registered investment adviser. Investment advisory services are offered by RJFSA and RJA through the IARs of RJFSA and RJA under the “doing business as” or “DBA” name of “Corporate Advisers Group”.

SHRM and Raymond James are not affiliated and SHRM is not authorized to provide investment advice on behalf of Raymond James or to act for or bind Raymond James. No investment advisory agreement with Raymond James will become effective until accepted by Raymond James.

Investment advisory fees represent the fees received by Raymond James from you pursuant to a written investment advisory agreement(s) between you and Raymond James.

The investment advisory fees you pay are neither reduced nor increased by the referral fee paid by Raymond James to SHRM. However, the presence of this arrangement may affect Raymond James’ willingness to negotiate below its standard investment advisory fees, and therefore may affect the overall fees you pay.