Rogers Investment Advisors, LLC

We begin our process with a detailed client interview that includes a discussion of the client's previous investment experience and preferences and the client's cash flow requirements, both currently and in the future. We also review recent client financial account statements and tax returns to fully understand the financial and tax positions of our clients.

Based on this information, our firm prepares a recommended asset allocation using various quantitative tools. The recommended asset allocation may include appropriate separate account managers, ETFs, mutual funds, fixed income security classes, etc. In some cases, we may recommend keeping certain existing securities, particularly index funds, municipal securities, certain legacy securities with large unrealized capital gains, or other similar core holdings, to the extent that they fit into the new optimized portfolio. We also provide a draft investment policy statement ("IPS") that is used to guide our firm's discretionary investment management activities going forward.

When our recommendations are ready, we meet with our clients for a second time to discuss the proposed asset allocation and IPS and obtain the client's final approval. Once the client is satisfied with the asset allocation and IPS, we begin our investment activity. We open new accounts for our client at Schwab Institutional as custodian and transfer the bulk of the client's financial assets to these new accounts. Once the client's assets have been received, we allocate the existing assets most efficiently to the various new asset classes in an attempt to minimize unnecessary asset sales. (This is obviously not a concern for tax free or tax advantaged accounts, however there may be tax consequences for taxable client accounts.) We work with clients on a tax strategy, but often many or most of the client's existing equity securities are sold because the new accounts typically have much greater diversification than the client's previous portfolios.

The timing of asset reallocation depends on market conditions, but it is typically completed with one or two months of receipt of client securities. In unsettled or bearish financial market conditions, we may temporarily adjust the asset allocation to a more defensive stance. Note that for assets that move into Managed Accounts, we are able to achieve asset-based pricing on the sale of the client's previous securities, so such assets should be transferred in kind and not liquidated before transfer to our firm. Except for checking accounts at local banks and other cash reserves, most of our clients transfer management responsibility for the vast majority of their investment securities to our firm. We prefer this approach because it allows us to see the total portfolio and develop an optimized approach to asset allocation and financial planning. This approach also is consistent with our high level of service. We typically set up monthly or quarterly disbursements to our client's bank checking accounts or to their mortgage lenders, etc. to pay recurring bills. This also helps at tax time, especially when our firm is preparing the tax returns for our client and when we are providing forward looking tax advice.

Once the IPS is agreed, RIA has discretion to invest client assets pursuant to the agreed asset allocation ranges. Many of our clients, who have typically done extensive estate planning, have multiple accounts, such as living trusts, charitable trusts, IRAs, foundations, college savings plans, etc. RIA works closely with our clients' existing legal and tax advisors to provided coordinated advice.

Our clients receive quarterly RIA combined reports, which show the performance of each asset class against relevant indices as well as consolidated results. The custodian separately provides monthly statements and trade confirms. For clients who prefer not to receive paper, trade confirms are available by e-mail and monthly statements, as well as up-to-date account information, are available on-line.

We generally meet with our clients on a quarterly basis to review the above performance reports and the client's financial situation. At each quarterly meeting, we may recommend adjustments to the client's IPS based on the changing situation, and we may recommend rebalancing the portfolio if the actual asset allocation has moved substantially from the agreed IPS. We specialize in tailoring our quarterly reviews and, indeed, regular client contact, to the needs of each client. Our goal is to explain to each client their financial situation, asset allocation and investment performance in a way that best suits them.