SCLC was organized to avoid conflicts of interest. We are independently owned, are not affiliated with any other provider of financial services company, and have no products to sell, other than our expertise. Virtually all of our revenues come from client fees. To avoid possible conflicts, we don’t consult to financial services companies that sell products to our clients. But it’s possible that some of our business practices might be construed as conflicts of interest. So we’ve thought hard about any possible conflicts, and have disclosed them below:

Possible Conflicts

This information supplements SCLC’s standard Disclosure Brochure (pdf) (which recapitulates in accessible English the information contained in Part II of Form ADV, which is filed with the Securities & Exchange Commission (SEC)). Please review this page in conjunction with the Disclosure Brochure.

In reviewing our business practices to identify possible conflicts of interest, we considered:

• Soft dollar arrangements with any broker dealer, research organization, or any like organization;
• Directed trades to any broker dealer that serve as consideration for any service or accommodation by any affiliated party to SCLC; and
• Relationships involving SCLC that could, in the reasonable opinion of a prudent person familiar with the circumstances, represent a conflict of interest.

Software Applications: Custodians/Broker Dealers

SCLC receives certain software applications at no charge from various Custodians/Broker Dealers with whom SCLC clients maintain relationships. These applications are designed for the mutual benefit of investment advisory firms (such as SCLC) and the Custodian/Broker Dealer. They facilitate the exchange of client information between advisory firms and the Custodian/Broker Dealer by permitting the Custodian/Broker Dealer to provide advisory firms with security position and price information, transaction information, trade confirmations and other similar data. They also permit advisory firms to provide the Custodian/Broker Dealer with trading instructions and client data required to establish and manage client accounts.

Although certain Custodians/Broker Dealers require that advisory firms maintain a minimum level of clients or assets in order to receive these applications at no cost, to the best of our knowledge, SCLC does not receive access to software applications that are not generally offered to other similar advisory firms.

Software Applications: Mutual Fund Companies

SCLC receives a software application at no charge from Dimensional Fund Advisors. The application provides information regarding the performance of the funds offered by DFA and the various indices on which the DFA funds are based.

To the best of our knowledge, SCLC does not receive access to DFA software applications that are not generally offered to other similar advisory firms.

Proprietary Websites

Custodians/Broker Dealers and Mutual Fund Companies maintain proprietary websites for investment advisory firms (such as SCLC). These websites provide information necessary to facilitate the relationship between the Custodian/Broker Dealers and investment advisory firms, such as descriptions of procedures, administrative forms, lists of securities offered, trading facilities, quotations, etc. Additionally, these websites include useful practice management information, such as articles on SEC compliance, best practices and marketing suggestions.

To the best of our knowledge, SCLC does not receive access to proprietary websites that are not generally offered to other similar advisory firms.

Newsletters/Research Papers

SCLC receives newsletters and research papers from Custodians/Broker Dealers and Mutual Fund Companies. These organizations send complimentary newsletters and research papers to investment advisory firms (such as SCLC). The newsletters and research papers cover a variety of topics, such as SEC compliance, investment theory, industry updates, product information, best practices, etc.

To the best of our knowledge, SCLC does not receive newsletters or research papers that are not generally offered to other similar advisory firms.

Conferences

Custodians/Broker Dealers and Mutual Fund Companies regularly offer conferences to discuss issues of interest to investment advisory firms (such as SCLC). SCLC regularly sends representatives to these conferences. Certain conferences are offered at no charge, others charge attendance fees, and some conferences charge attendance fees but waive them for SCLC representatives.

To the best of our knowledge, SCLC does not receive any conference invitations or fee waivers that are not generally offered to other similar advisory firms.

Referral Programs

Custodians/Broker Dealers and Mutual Fund Companies periodically refer clients to investment advisory firms (such as SCLC). Some Custodians/Broker Dealers maintain structured referral programs. SCLC receives client referrals from Custodians/Broker Dealers and Mutual Fund Companies under both structured and informal referral programs.

Although certain referral programs require that advisory firms maintain a minimum level of assets with the Custodian/Broker Dealer in order to participate in the structured referral program, to the best of our knowledge, SCLC does not participate in any such programs.