Disclosure

DISCLOSURE

Investment advisory services offered through Horter Investment Management, LLC, a SEC-Registered Investment Advisor. Horter Investment Management does not provide legal or tax advice. Investment Advisor Representatives of Horter Investment Management may only conduct business with residents of the states and jurisdictions in which they are properly registered or exempt from registration requirements. Insurance and annuity products are sold separately through Black Swan Retirement Solutions, LLC. Securities transactions for Horter Investment Management clients are placed through Trust Company of America, TD Ameritrade and Jefferson National Life Insurance Company.

Low Risk, Low Volatility Disclosure: Your investment advisor may recommend third-party money managers who utilize investment strategies designed to minimize portfolio volatility and reduce the risk of declines in account values. Like any other investment strategy, this approach entails risks, including the risk that client accounts can still lose value and the risk that a defensive position may, at any given point in time, prevent client accounts from appreciating in value.

We describe the Horter investment management platform by using the terms "Low Risk" and "Low Volatility" to emphasize the strategies employed by our money managers. However, notwithstanding the risk management strategies employed by these money managers, certain investment portfolios employed by our money managers present a greater degree of investment risk than others depending upon the performance of the underlying securities. We typically refer to these strategies as "Moderate Risk" and "Moderate Volatility". Such performance can be impacted by a number of risk factors, including but not limited to (i) the level of price volatility (equity securities generally have greater price volatility than debt securities, (ii) changes in interest rates, and (iii) the ability of the manager to purchase or sell a security in a timely manner at desired prices.

Insurance and annuity products are not sold through Horter Investment Management, LLC (“Horter”). Horter does not endorse any annuity or insurance products nor does it guarantee their performance. Owners of these products are subject to the terms and conditions of the policies and contracts of the issuing companies. All product guarantees depend on the insurance company’s financial strength and claims-paying ability.

Additional Investment Advisory Notices of Privacy Practices

In 1999, Congress passed the Gramm-Leach Bliley Act (the "GLBA") in an effort to modernize the American financial markets. In connection with modernizing the financial marketplace, GLBA established standards for how financial institutions must protect the privacy of consumer financial information.


Under GLBA, the definition of financial institutions includes investment advisers. As an investment adviser, Horter Investment Management, LLC ("Horter Investment"), is subject to the provisions of the GLBA and is committed to protecting the privacy of its clients' nonpublic personal financial information. The following information clarifies Horter Investment's privacy practices and is published for you because of this law.


As part of its business practices, Horter Investment obtains certain nonpublic personal financial information about its Clients. This information includes, but is not limited to, the following: data received from you on applications or other forms (e.g., your name, address, social security and accounts at other institutions); information about your transactions with us, or affiliates, or others; and information received from third-party sources.


Horter Investment restricts access to nonpublic personal financial information to authorized parties who need this information in the course of providing services and products to our clients and maintains physical, electronic and procedural safeguards to protect such information.


Horter Investment does not disclose, and does not wish to reserve the right to disclose, any of its clients' nonpublic personal financial information to affiliates or nonaffiliated third parties, except under the limited exceptions for processing and servicing transactions, or any other legal requirements. Horter Investment also does not disclose, and does not wish to reserve the right to disclose, nonpublic personal financial information of former clients to affiliates or nonaffiliated third parties, except under the limited exceptions for processing and servicing transactions, or any other legal requirements.


Horter Investment discloses its clients' nonpublic personal financial information only as permitted or required by law or consented to by each client.