The investment program provides clients of Mile Marker Financial Advocates the opportunity to meet their long-term financial goals through the use of model and customized portfolios as part of broader, comprehensive wealth management process.

The following objectives have been established in conjunction with a comprehensive review of client needs throughout their investment lives and options available on behalf of the clients of Mile Marker Financial Advocates:

• Navigate market conditions within the context of a full investment cycle.
• Maintain investment flexibility in meeting the long-term goals and objectives of our clients.
• Provide clients with investment strategies to accommodate the variation in risk profiles across our client base.
• Control costs of administering the investment program and managing the assets
• Comply with all fiduciary, prudence, and due diligence requirements.

Molly Rambo, CPFA, is a fiduciary to the program and is responsible for providing the investment framework and monitoring the investment management program for clients and investors.

Molly is authorized to engage with professional experts in the field to help fulfill the fiduciary responsibilities to clients and their beneficiaries.

Consultants may be engaged to provide non-discretionary consulting services consistent with the investment objectives, policies and constraints established in this document.

Investment Managers may be engaged to provide investment management services for client assets. Investment managers can include both actively and passively managed mutual funds, exchange traded funds, collective investment trust, separate accounts and other types of investments.

Additional specialists such as attorneys may also provide services to the program to assist in meetings its responsibilities and obligations to clients, investors and beneficiaries.

Clients have the responsibility of providing all the information necessary to make an informed recommendation, including but not limited to:

Basic KYC Data
Basic Know Your Client information is required by both law and necessity, in order to properly evaluate the clients’ current situation.

Objectives
Investment objectives are desired outcomes of investments and generally pertain to return and risk.

Constraints
Constraints are limitations on the ability to take full or partial advantage of particular investments.

Risk Profiling
Establishing an investment risk profile is an essential part of structuring an investor's investment portfolio

Molly Rambo, in consultation with investment committee, subject matter experts, consultants, and other advisors, seeks to provide clients with a broad array of model portfolios that could represent a variety of levels of risks vs. return profiles and time horizon constraints.

The investment program seeks to achieve broad based diversity in the model portfolios offered, using certain criteria to determine the material differences between the potential strategies offered while making use of a disciplined exposure to a wide variety of asset classes.

Criteria parameters are as follows:

• A distinct and definable investment universe of securities carefully vetted and selected for potential inclusion.
• A distinct risk and return profile.
• A distinct management style that can be defined in terms of the investment strategies methodologies utilized (passive vs. active, for example.)
• Where appropriate, custom portfolios will be created to meet the specific needs of clients whose best interest would not be served by the use of a model portfolio.
• Molly reserves the right to add or replace model portfolios and underlying securities contained within based upon changes in market conditions, strategic outlook, investment committee, topic expert and consultant input, account owner input, and/or other factors.
• The guidelines set forth in any pertinent prospectus or trust document shall govern all mutual funds, ETF, separate accounts, collective investment trusts, and closed-ended funds.

Molly Rambo's investment beliefs provide a foundational framework for the decision-making process. Our beliefs guide the development of appropriate policy, procedures, and  investment decisions for advisor managed portfolios.

Molly will conduct an on-going thorough analysis with the assistance of subject matter experts, consultants and other advisors deemed necessary to fulfill their fiduciary obligations of procedural due diligence.

The following is a non-exhaustive set of investment beliefs that help guide us:

• Asset allocation is the primary determinant of portfolio return and volatility.
• Portfolio diversification plays a critical role in improving risk adjusted returns.
• Risk is multi-dimensional and while it cannot be simplified into one precise measure, a range of steps can be taken to evaluate and assess risk for both our portfolios and clients.
• Portfolios should be constructed in a way that help clients navigate various market environments that make up a full business cycle.
• Investment strategies should be proactively managed based on forward looking insights, rather than simply on "what's worked" in the past.
• Some asset classes are more efficient than others and therefore have varying opportunities in our clients’ portfolios. When working with an efficient asset class it is generally better to use passive management while when using less efficient asset classes there tends to be more value in using active management.  
• Investment costs have a significant impact on long term portfolio performance. Costs must be measured, monitored and prudently managed whenever possible.

Molly Rambo recognizes the role that an effective Strategic Asset Allocation policy will play in helping clients manage risk and return objectives as they pursue their long-term goals.

Strategic asset allocation is determined by Molly through appropriate research and analysis conducted internally as well as with the help of external consultants, subject matter experts and other advisors.

Molly evaluates a wide range of data, assumptions, and inputs, including but not limited to expected:

• Rates of return expectations for each asset class.
• Variability of each asset class and correlations of each asset class with those of other asset classes. 
• Expected performance of each asset class in response to different market conditions. 
• Costs of accessing the desired asset class

Molly Rambo has the responsibility and  sole discretion for selecting the underlying investment managers of the investment portfolios that are available unless otherwise instructed by the account owner.

Molly  will conduct thorough analysis with the assistance of subject matter experts, consultants and other advisors deemed necessary to fulfill their fiduciary obligations of procedural due diligence.

The following is a non-exhaustive set of criteria that will be considered: 

• Organizational structure of the Investment Manager. 
• Long term performance track record.
• Performance evaluation reports illustrating the risk/reward profile of the investment manager relative to other similar managers of like investment style, as appropriate. 
• Detailed information on the history of the firm, key personnel, and costs. 
• Adherence to the stated investment strategy over time. 
• Fees that are competitive compared to similar investments

Molly Rambo recognizes the importance of ongoing review and analysis of underlying investment managers, model portfolios, and custom portfolios. The process for monitoring the strategies and investment managers is as follows:

1. On-going Monitoring - A qualification analysis of all investment managers will be conducted at minimum of once per year. In addition to reviewing on-going performance, the program manager will continually evaluate:

• Material changes in the investment managers organization, investment philosophy, and/or personnel.
• Investment manager adherence to the IPS guidelines. 
• Comparisons of the investment managers results to appropriate indices, peer groups and comparable investment strategies.
• Performance, risk and efficiency measurements compared to the related measurements of the appropriate market index and peer group.If appropriate markets indices and/or peer groups are not available, Molly will evaluate factors consistent with stated objectives, including but not limited to, risk and return, philosophy, process and exposures in relation to the market environment.

2. Formal Watchlist -  If Molly determines that any of the above factors, or any other developments regarding underlying investment manager's performance or organization needs a more thorough examination, she will place the investment manager on a formal watchlist.  Length of watchlist period is at the sole discretion of Molly.

One of the key reasons for the rebalancing is that material deviations from strategic target weightings can impair the portfolios ability to meet its long term goals and objectives. Rebalancing seeks to balance the risks associated with target allocation deviations with the cost of transacting. Under normal market conditions, investment portfolios will be rebalanced twice a year, once in January and once in July. 

Molly Rambo will monitor actual asset allocation relative to targets and allowable ranges, as well as underlying market conditions to evaluate the need for additional rebalancing. Molly reserves the right to partially or fully rebalance the portfolio as necessary, while taking into account the transaction costs associated with any given portfolio rebalancing.