An investment advisor firm registered with the U.S. Securities and Exchange Commission (“SEC”) must meet certain requirements concerning the delivery of the investment advisor firm’s disclosure brochure Form ADV Part 2A. Under SEC Rule 204-3(b), each year, within 120 days of the investment advisor firm’s fiscal year end, the investment advisor firm must deliver to every client an updated disclosure brochure that includes a summary of material changes or deliver to every client a summary of material changes that includes an offer to provide a copy of the updated disclosure brochure and information on how a client may obtain the brochure.

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