Schwab Disclosure

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Websites Introduction

Prior to linking to either the Schwab Alliance Website (www.schwaballiance.com, the “Schwab Alliance Website”) or to the public portion of the Schwab Website (www.Schwab.com, or the Schwab Public Website,” and together with the Schwab Alliance Website, the “Schwab Sites”), you must obtain Schwab’s written
consent and adhere to the requirements described in further detail below. Schwab reserves the right to withdraw its permission with respect to any link which does not follow these required guidelines.

The Schwab Alliance Website: www.SchwabAlliance.com

When your clients access the Schwab Alliance Website, they will have access to a variety of financial and cash management tools. Features may include, but are not limited to, account information, trading capabilities, cash management services and Schwab’s retail research and tools. This Website is largely modeled after the retail version of www.Schwab.com. Where possible, modifications have been made in the positioning and verbiage within the site in consideration of the client and investment manager relationship.

The Schwab Public Website: www.Schwab.com

The www.Schwab.com public site is an unsecured site that contains general Schwab company information and product marketing information. Any client or prospect can access this site via the www.schwab.com URL. There is no access to secured features such as account information, trading, or cash management on the Schwab Public Website.

Schwab generally does not object to links that comply with these guidelines. A firm’s link must not compromise the integrity of Schwab’s intellectual property or create any confusion as to the relationship between Schwab and the firm. In addition, links must not create any possibility of legal or regulatory issues.

We suggest that you consult with your own legal counsel regarding your responsibilities with respect to the content on your site and the sites to which you establish electronic links.

Schwab cannot guarantee that any links to the Schwab Sites will continue to be acceptable in the future. Accordingly, we must reserve the right to change these guidelines and our position with respect to any link to the Schwab Sites.

Requirements for Linking

Firms must comply with the following:

  1. www.Schwaballiance.com—Any link from the firm’s site must be to the Schwab Alliance Website homepage only. No other portions of Schwab’s Website may be used. The Schwab Alliance homepage URL is www.schwaballiance.com.
  2. www.Schwab.com—When linking to the Schwab Public Website, the following URL must be used: www.schwab.com.
  3. After the link has been established, Schwab reserves the right to periodically review the link to assure that it has not changed in any material fashion. If your site is password protected, please provide a user ID and password to your site on the submission form. This password information should remain active as long as you are linking to the Schwab Alliance Website or the Schwab Public Website.
  4. The firm’s Website must display a click-through disclosure page, which must appear after the user clicks on the link to the applicable Schwab Site. The required disclosure is shown below.
  5. The firm must comply with the consent guidelines detailed below.

You may choose to launch a new browser from your firm’s Website to provide access to the Schwab Alliance Website or Schwab Public Website. The following provides specific guidelines to link to the Schwab Sites. Before you link to either of the Schwab Sites, you must set up a prototype and obtain prior consent from Schwab. A prototype is a functional test site which is either password protected or under a test URL address. When completing your submission form,
please provide password information and/or the test site URL for viewing the prototype.

IMPORTANT NOTICE

You are now leaving the IRA Group Website and will be entering the Charles Schwab & Co., Inc. (“Schwab”) Website.

Schwab is a registered broker-dealer, and is not affiliated with IRA Group or any advisor(s) whose name(s) appears on this Website. IRA Group is/are independently owned and operated. Schwab neither endorses nor recommends [Name(s) of Investment Management Firm(s)] [./, unless you have been referred to us through the Schwab Advisor Network®. (This bracketed language is for use by Schwab Advisor Network members only.)] Regardless of any referral or recommendation, Schwab does not endorse or recommend the investment strategy of any advisor. Schwab has agreements with IRA Group under which Schwab provides IRA Group with services related to your account. Schwab does not review the IRA Group
Website(s), and makes no representation regarding the content of the Website(s). The nformation contained in the IRA Group Website should not be considered to be either a recommendation by Schwab or a solicitation of any offer to purchase or sell any securities.