Chao & Company embraces the fiduciary culture and understands the delicate nature of trust and the fiduciary relationship. As a fiduciary to our investment clients, we avoid conflicts so that divided loyalty is never an issue. Transparency, good faith, full disclosure, integrity and the adherence of fiduciary laws and standard of conducts form the foundation of our fiduciary culture. To serve as an investment fiduciary, it is not enough just to serve in the best interest of our clients and to demonstrate good faith. The element of due care is also owed. This duty requires us to perform in a like-kind manner of a similarly situated prudent expert. We must take reasonable steps on a best effort basis to research, analyze, enquire, and verify our investment due diligence process and to challenge our own thinking and conventional wisdom. Our clients leave their properties in our care, and in turn, we must deliver the highest standard of practice and diligence so that their best interests are served.

Chao & Company, an investment adviser registered with the U.S. Securities and Exchange Commission, serves in a fiduciary capacity for its clients. In addition, under the dictates of ERISA, we serve in the following fiduciary capacities:

Limited-Scope 3(21) –

Render advice as a co-fiduciary to the Plan Sponsor and/or participants. Such advice is acted upon at the discretion of the Full-Scope 3(21) fiduciary or participant.

Full-Scope 3(21) –

Authorized to select and terminate Plan investment managers and service providers and render investment advice.

Discretionary 3(38) –

Appointed with full power to manage, acquire, or dispose of any asset of a plan, thereby relieving the plan sponsor or Full-Scope 3(21) from their fiduciary liability for the investment decisions.