PERFORMANCE DISCLOSURES

THE RISK OF LOSS

When making investments in equity securities, there is a risk that a portion or 100% of your investment funds could be loss. The RESOURCE CAPITAL LONG PORTFOLIO is an investment in equity securities. RESOURCE CAPITAL’s management attempts to invest 90% to 95% of a clients managed account into equity securities.

Disclosure Requirements for Investment Advisers

Investment advisers provide a wide range of advisory services and play an important role in helping individuals and institutions make significant financial decisions. To allow clients and prospective clients to evaluate the risks associated with a particular investment adviser, its business practices, and its investment strategies, it is essential that clients and prospective clients have clear disclosure that they are likely to read and understand. That is why the Securities and Exchange Commission (SEC) has adopted amendments to Part 2 of Form ADV to require investment advisers to provide new and prospective clients with a brochure and brochure supplements written in plain English. These amendments are designed to provide new and prospective clients with clearly written, meaningful current disclosure of the business practices, conflicts of interest, and background of the investment adviser firm and the firm’s employees who provide advice.

What is Form ADV?

Form ADV is the uniform form used by investment advisers to register with both the SEC and state securities authorities. The form consists of two parts. Part 1 requires information about the investment adviser’s business, ownership, clients, employees, business practices, affiliations, and any disciplinary events of the adviser or its employees. Part 1 is organized in a check-the-box, fill-in-the-blank format. The SEC reviews the information from this part of the form to manage its regulatory and examination programs. Although designed for a regulatory purpose, investment adviser filings of Part 1 are available to the public on the SEC’s Investment Adviser Public Disclosure (IAPD) website at www.adviserinfo.sec.gov.

Part 2 requires investment advisers to prepare narrative brochures that include plain English disclosures of the adviser’s business practices, fees, conflicts of interest, and disciplinary information. The brochure is the primary disclosure document for investment advisers. Investment advisers are required to deliver to advisory clients their brochures, which will be made available to the public on the IAPD website.

Amendments to Part 2 of Form ADV

As amended, Part 2 of Form ADV now includes two sub-parts, Part 2A and Part 2B. Part 2A contains 18 disclosure items to be included in the investment adviser’s brochure. In addition, investment advisers will now be required to deliver annually to clients a summary of material changes to the brochure along with either a revised brochure or an offer to deliver a copy of the revised brochure. Part 2B is called the “brochure supplement” and includes information about the specific individuals, acting on behalf of the investment adviser, who actually provide the investment advice and interact with the client.

Brochure

Investment advisers must provide their prospective and existing clients with a narrative brochure written in plain English. As amended, Part 2A of Form ADV contains 18 separate items, each covering a separate disclosure topic, to be included in the brochure. To make it easier for investors to compare the brochures of different investment advisers, advisers must respond to each item in Part 2A in the order listed in the form, using the same headings provided by the form. Much of the disclosure required in Part 2A addresses an investment adviser’s conflicts of interest with its clients, and is disclosure that an investment adviser, as a fiduciary, must make to clients. The required disclosures include:

Advisory business – An investment adviser must describe its advisory business, including the types of advisory services offered, whether it holds itself out as specializing in a particular type of advisory service, and the amount of client assets that it manages.
Fees and compensation – An investment adviser must describe in its brochure how it is compensated for its advisory services, provide a fee schedule, and disclose whether fees are negotiable. The investment adviser must also disclose whether it bills clients or deducts fees directly from clients’ accounts, or whether the client may select either method, and how often it assesses fees. In addition, the investment adviser must describe the types of other fees or expenses, such as brokerage, custody fees, and fund expenses that clients may pay in connection with the advisory services provided to them by the investment adviser.
Performance-based fees and side-by-side management – An investment adviser that accepts performance-based fees or that supervises an individual who accepts such fees must disclose this fact. If the investment adviser also manages accounts that are not charged a performance fee, the adviser must explain the conflicts of interest that arise from the simultaneous management of these accounts and must describe how it addresses those conflicts.
Methods of analysis, investment strategies, and risk of loss – Investment advisers must describe their methods of analysis and investment strategies and explain that investing in securities involves risk of loss which clients should be prepared to bear. Investment advisers must also explain the material risks involved for each significant investment strategy or method of analysis they use and for any particular type of security they recommend primarily. Investment advisers must explain those risks in greater detail if the risks are unusual or significant. If the primary strategy involves frequent trading of securities, investment advisers must explain specifically how frequent trading can affect investment performance.
Disciplinary information – An investment adviser must disclose in its brochure material facts about any legal or disciplinary event that is material to a client’s evaluation of the advisory business or of the integrity of its management personnel. Certain disciplinary events are presumed to be material if they occurred within the last 10 years. An investment adviser must deliver promptly to clients updated information regarding disciplinary events if it is updating a brochure to add a new event or to change material information about a disciplinary event.
Code of ethics, participation or interest in client transactions, and personal trading – An investment adviser must describe briefly its code of ethics and state that a copy is available upon request. If the investment adviser or a related person recommends to clients, or buys or sells for client accounts, securities in which the adviser or related person has a material financial interest, the adviser must describe this practice and the conflicts of interest presented by such a practice. An investment adviser must also disclose whether it or a related person invests in the same securities that it recommends to clients or in related securities, such as options or other derivatives, and must describe the practice and discuss the conflicts involved and how it addresses those conflicts. In addition, an investment adviser that trades in the recommended securities at or around the same time as the client must describe the practice and discuss the conflicts presented by that practice and how the adviser addresses them.
Brokerage practices – Investment advisers must describe the factors that they consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of brokers’ compensation. Investment advisers must also disclose soft dollar practices (research or other products or services, other than execution, provided by brokers or a third party to the investment adviser in connection with client transactions); client referrals (using client brokerage to compensate brokers for client referrals); directed brokerage (asking or permitting clients to send trades to a specific broker for execution); and trade aggregation (bundling trades to obtain volume discounts on execution costs). Investment advisers are required to explain how they address the various conflicts of interest associated with these practices.

Brochure Supplement

Part 2B of Form ADV is called the “brochure supplement.” An investment adviser must give a client a brochure supplement for each individual that it supervises who: (1) formulates investment advice for that client and has direct client contact; or (2) makes discretionary investment decisions for that client’s assets, even if the supervised individual has no direct client contact.

The brochure supplements contain information about the educational background, business experience, and any disciplinary history of the specific individuals who provide advisory services to the client. Brochure supplements may be separate documents or incorporated into the firm brochure. An investment adviser must deliver a brochure supplement that provides information about an employee either before or at the time that the employee begins to provide investment advice to a client. The investment adviser must deliver promptly to clients updated information regarding disciplinary events if it is updating a brochure supplement to add a new event or to change material information about a disciplinary event.

Part 2B of Form ADV consists of six items, including:

Educational background and business experience – The brochure supplement must describe the supervised individual’s formal education after high school and his or her business experience for the past five years.

Disciplinary information – The brochure supplement must disclose any legal or disciplinary event that is material, and include certain disciplinary events that are presumed to be material to such an evaluation if they occurred during the last 10 years.

Other business activities – The brochure supplement must describe the supervised individual’s other business activities and any material conflicts of interest that such participation may create. It must also include information about any compensation – bonus or non-cash – that the supervised individual receives based on the sales of securities or other investment products, as well as an explanation of the incentives this type of compensation creates.

Additional compensation – The brochure supplement must describe arrangements in which somebody other than the client provides the supervised individual an economic benefit, such as a sales award or other prize, for providing advisory services.

Supervision – An investment adviser must explain how it supervises the supervised individual, including how it monitors the advice provided to the client by the supervised individual and must include the name, title, and telephone number of the individual’s supervisor.

If investment advice is provided by a team comprised of more than five supervised individuals, brochure supplements need only be provided for the five supervised individuals with the most significant responsibility for the day-to-day advice provided to the client.

Brochure supplements are not filed with the SEC. However, the public can obtain information about advisory personnel, including disciplinary information, through the IAPD system at http://www.adviserinfo.sec.gov.

PERFORMANCE DISCLOSURE FOR THE RESOURCE CAPITAL LONG 60 MODEL PORTFOLIO

Performance data is reported net of a 1% advisory fee but does not include taxes, custodian, brokerage or other applicable fees. Past performance is no guarantee of future results and current performance may be higher or lower than the performance shown. The investment return and the principal value of an investment will fluctuate so that an investor’s shares, when redeemed may be worth more or less than their original cost. Investment involves risks such as fluctuating value and the possibility of loss of capital. Results are dependent upon market and or economic conditions.

The firm’s investment model and process has been developed via extensive research and extensive programming. The firm’s investment model is a static model that utilizes limitation filters to construct unique universes of equity securities which are segmented into specific sectors. The investment model utilizes several fundamental financial factors to calculate a score for each equity security in order to rank the security within a specific sector. If there is a tie score within a sector, the investment model utilizes certain fundamental financial factors as tie breakers. Once the equity securities are ranked, equity portfolios are then constructed by the investment model. The firm’s equity portfolio construction method has been back tested using stock exchange data from 1985 to 2009 and implemented on Model Portfolios from December 31, 2009 to December 31, 2014 (Reviewed by Ashland Partners) and from January 1, 2014 to December 31, 2015 (Not Reviewed by Ashland Partners). Throughout the back testing phase utilizing 25 years of data and the 4 years of the Model Portfolio, the equity portfolios constructed by the firm’s investment model have outperformed the RUS 1000 TR VALUE INDEX annually.

Supplemental: Supplemental information is for illustrative purposes only. The supplemental information in this document does not represent the results of actual investment. No assurances can be made as to the actual investment performance which could have been achieved.

Model Portfolios: The time period from December 31, 2009 to December 31, 2014 (Reviewed by Ashland Partners) and from January 1, 2014 to December 31, 2015 (Not Reviewed by Ashland Partners) disclosed in this document represent Model Portfolios ONLY. No actual investment was made in the Model Portfolios and therefore no assurances can be made as to the actual investment performance which could have been achieved. As such, any financial or performance calculations in this document utilizing data from December 31, 2009 to December 31, 2014 (Reviewed by Ashland Partners) and from January 1, 2014 to December 31, 2015 (Not Reviewed by Ashland Partners) are based solely on Model Portfolios and not Live Money Portfolios.

Investment Returns

The Investment returns include dividends and capital gains. Returns are net of Resource Capital’s maximum advisory fee of 1% of assets under management billed annually or quarterly in arrears. Returns for periods of less than one year are actual returns and returns for periods greater than one year are annualized returns.

The Resource Capital Long 60 Model Portfolio has the following characteristics:

The model portfolios are comprised of publicly traded equity stocks. The companies have a minimum market capitalization between $2 billion and $10 billion and are considered “mid- to large-cap” companies.
The model portfolios reflect total return results.
Concentration: All stocks in the portfolios are equally weighted within the portfolio and equally weighted across sectors.
The investment objectives of the RCM Long 60 Model Portfolio are capital appreciation and value investing.
The firm’s investment model is a static model that utilizes limitation filters to construct unique universes of equity securities which are segmented into specific sectors.
Resource Capital has managed the model portfolio with the same investment philosophy it uses for client accounts.

Performance Disclosure:

The Resource Capital Long 60 Model Portfolio performance represents only the results of Resource Capital model portfolios. The model performance has inherent limitations. The returns shown are model results only and do not represent the results of actual trading of investor assets. Thus, the performance shown or discussed does not reflect the impact that material economic and market factors had or might have had on decision making if actual investor money had been managed. While model performance may have performed better than the benchmark for some or all of the periods shown, the performance during any other period may not have, and there is no assurance that model performance will perform better than the benchmark in the future. An investor's actual portfolio, composition and performance of the account may differ from those of the model portfolio due to differences in the timing and prices of trades, and the identity and weightings of securities holdings. Performance is calculated using a time-weighted rate of return using daily valuations and takes into account the reinvestment of dividends. Dividends are assumed to be paid at the ex-dividend date. Stocks are presumed added to, or deleted from, the model portfolio at the close of market on the day the change is made. The model performance reflects the deduction of a 1% advisory fee, but does not consider taxes and brokerage commissions, or other fees that investors may incur.

Benchmark Disclosure:

The benchmarks for the Resource Capital Long 60 Model Portfolio are the Russell 1000 Total Return Index, the Russell 1000 Value total Return Index and the S&P 500 Total Return Index. The selected indices are not presented as appropriate benchmarks for the portfolios. The benchmarks are presented for illustrative purposes only. An index is an unmanaged, statistical composite and its return does not reflect payment of any brokerage commissions or fees an investor would pay to purchase the securities it represents. Such costs would lower performance. It is not possible to invest directly in an index. The benchmarks include a different number of securities and have different risk characteristics than the model portfolios. Past performance of the benchmark is no indication of future returns.

Russell 1000 Total Return Index

The Russell 1000 Total Return Index measures the performance of the large-cap segment of the S. equity universe. A subset of the Russell 3000 Index, it includes approximately 1,000 of the largest stocks and represents approximately 90% of the U.S. market. The total return version reflects the effects of dividend reinvestment.

Russell 1000 Value Total Return Index

The Russell 1000 Value Total Return Index measures the performance of the large-cap value segment of the S. equity universe, and includes those Russell 1000 companies with lower price-to-book ratios and lower expected and historical growth rates. The total return version reflects the effects of dividend reinvestment.

S&P 500 Total Return Index

The S&P 500 Total Return Index is an index of 500 stocks seen as a leading indicator or S. equities and a reflection of the performance of the large-cap universe. It is a market value weighted index and one of the common benchmarks for the U.S. stock market. The total return version reflects the effects of dividend reinvestment.

THE RISK OF LOSS: When making investments in equity securities, there is a risk that a portion or 100% of your investment funds could be loss. The RESOURCE CAPITAL LONG 60 MODEL PORTFOLIO is an investment in equity securities.

The Model Portfolios from December 31, 2009 to December 31, 2014 (Reviewed by Ashland Partners) and from January 1, 2014 to December 31, 2015 (Not Reviewed by Ashland Partners) were developed and constructed by the Resource Capital financial model. The Resource Capital financial model is a static model. The model utilizes limitation filters to construct a unique universe of equity securities and segments the securities into specific sectors. The model utilizes fundamental financial factors to rank securities within sectors. The financial factors utilized in the ranking process of the Model Portfolios encompass quantitative as well as qualitative measures of equity securities. Once the equity securities were ranked, the Model portfolios that were constructed were comprised of either, 20, 40, 60 or 100 equity securities.

The Model Portfolio construction process had four distinct phases.

The first phase was a screening process that filtered and reduced a larger universe of equity securities into a unique and firm relevant universe.
The second phase generated a score for each equity security.
The third phase segmented the equity securities into sectors and then distinctly ranked the equity securities within the sector.
The fourth phase selected the top ranking equity securities within each sector for inclusion into the Model Portfolios.

The Model Portfolio Simulated Purchase

The equity securities for the Model Portfolios were selected on December 31, 2009, December 31, 2010, December 31, 2011, December 31, 2012 and December 31, 2013 (Reviewed by Ashland Partners)
The equity securities for the 2015 Resource Capital Long 60 Model Portfolio were selected on December 31, 2014 (Not Reviewed by Ashland Partners).
The Model Portfolio equity securities were selected and recorded at the close price of the last trading day of the current year or at the open price of the first trading day of the next year.
The Model Portfolios were not actually purchased. The December 31 close prices of a respective year or the January 1 opening prices of a respective year were utilized as the Model Portfolios stock prices. The prices were utilized in order to make simulated purchases of the Model Portfolio. The simulated purchase of the Model Portfolio was made by taking the total dollar amount of the investment and making equal dollar amount investments in each of the Model Portfolio’s equity security regardless of the security’s price. Therefore there was an equal weighting across all stocks and sectors that comprised the Model Portfolios.
All of the Model Portfolio equity securities were held in the portfolio for one year.
No equity securities were added or removed from the Model Portfolio during the one year holding period.
At the end of the year, the Model Portfolios were rebalanced on December 31 and a new portfolio was established for the next year.

Back-Tested Portfolios

Each back-tested Resource Capital long portfolio from January 1, 1985 to December 31, 2009 was constructed by the Resource Capital financial model utilizing the same fundamental factors, portfolio construction and execution processes.
The performance history is compiled by looking back in time and applying a pre‐specified strategy trading discipline to derive strategy performance. Back tested performance was derived from the retroactive application of a model with the benefit of hindsight.
Modeled results may differ materially from actual results as they do not represent actual trading and may not fully account for commissions and other expenses a client would have paid. Modeled results may not reflect the impact that material economic and market factors might have had on the adviser’s decision making if the adviser were actually managing the client’s money.
The performance results shown include the reinvestment of dividends and other earnings. The U.S. Dollar is the currency used to express performance. Additional information regarding the calculation methodology is available upon request.
Actual performance would be reduced by investment advisory fees and other expenses that may be incurred in the management of the client’s portfolio. The collection of fees produces a compounding effect on the total rate of return net of management fees. As an example, the effect of investment management fees on the total value of a client’s portfolio assuming (a) quarterly fee assessment, (b) $1,000,000 investment, (c) portfolio return of 8% a year, and (d) 1.00% annual investment advisory fee would be $10,416 in the first year, and cumulative effects of $59,816 over five years and $143,430 over ten years. Actual investment advisory fees incurred by clients may vary.
It should not be assumed that all clients follow the Model. Actual client investments are made with the client’s investment objective, risk tolerance and income needs in mind.

The Model Portfolio

Each Model Portfolio from December 31, 2009 to December 31, 2014 (Reviewed by Ashland Partners) and from January 1, 2014 to December 31, 2015 (Not Reviewed by Ashland Partners) was constructed by the Resource Capital financial model utilizing the same fundamental factors, portfolio construction and execution processes that were utilized to construct each back-tested portfolio from January 1, 1985 to December 31, 2009.

From December 31, 2009 to December 31, 2014 (Reviewed by Ashland Partners) and from January 1, 2014 to December 31, 2015 (Not Reviewed by Ashland Partners) the Resource Capital Long 60 portfolios were either forwarded to parties, notarized and or mail stamped for verification, purchased by the company, by other companies or by individuals who received the December 31, or March 30 of 2014 Resource Capital Long 60 stock selections. There can be no assurances that any individual and or entity actually purchased the Resource Capital Long 60 Portfolio stock selections. Only return performances for 2016 can be verified via actual trades made by the firm and or its personnel via Folio Investing, Inc. When making investments in equity securities, there is a risk that a portion or all of your investment funds could be lost. The Resource Capital Long Portfolio is an investment in equity securities.

Calculation Disclosures: The time frames used for the Annualized Rolling Return Calculation, The 3 Year Quarterly Rolling Return Calculation and the Standard Deviation Calculation were from December 31, 2009 to December 31, 2014 (Reviewed by Ashland Partners) and from January 1, 2014 to December 31, 2015 (Not Reviewed by Ashland Partners).

Annualized Rolling Return Calculation Disclosure

The Rolling Return calculation is based on determining the geometric return over a given 12 month period. For example, the twelve month period could be from January 1 to January 1, from February 1 to February 1 or from July 1 to July 1. The assumption for this calculation is that some investors may invest in the Resource Capital Long 60 during different times of the year. As such, the expected return generated from January 1 to January 1 may be different than the returns generated from February 1 to February 1 or from July 1 to July 1. Rolling Return is a process of dividing time frames into equal parts and taking the average of period returns which can give additional information about the performance of the Resource Capital Long 60 Portfolio over different time periods. As such, the Rolling Return calculation is an attempt to provide an investor with more information in order to evaluate the performance of the Resource Capital Long 60 portfolio during different time periods. The following is how the Annualized Rolling Return is calculated for each annual time period:
- ((1+ Return1)*(1+ Return2)*(1+ Return3)*(1+ Return 4)*(1+ Return 5)*(1+ Return 6)*(1+ Return 7)*(1+ Return 8)*(1+ Return 9)*(1+ Return10)*(1+ Return 11)*(1+ Return 12))-1

3 Year Quarterly Rolling Return Calculation Disclosure

The Rolling Return calculation is based on determining the geometric return over a given three year quarterly period. For example, the three year period could be from January 1 (year 1) to December 31 (year 3). The assumption for this calculation is that some investors may invest in the Resource Capital Long 60 during different times of the year. As such, the expected return generated from January 1 (year 1) to December 31 (year 3) may be different than the returns generated from July 1 (year 1) to June 30 (year 3). Rolling Return is a process of dividing time frames into equal parts and taking the average of period returns which can give additional information about the performance of the Resource Capital Long 60 Portfolio over different time periods. As such, the Rolling Return calculation is an attempt to provide an investor with more information in order to evaluate the performance of the Resource Capital Long 60 portfolio during different time periods. The following is how the Annualized Rolling Return is calculated for each annual time period:
- ((1+ Quarter1)*(1+ Quarter2)*(1+ Quarter3)*(1+ Quarter 4)*(1+ Quarter 5)*(1+ Quarter 6)*(1+ Quarter 7)*(1+ Quarter 8)*(1+ Quarter 9)*(1+ Quarter10)*(1+ Quarter 11)*(1+ Quarter 12))-1

Standard Deviation Calculation Disclosure

Resource Capital uses an annualized standard deviation figure as an approximation or estimate because the annualized figure is the most common way of presenting standard deviation. In addition, it provides a measure that may be readily compared to Morningstar and other advisor’s standard deviation calculations. Resource Capital calculates the annualized standard deviation by multiplying the monthly standard deviation measure by the square root of the number of periods in a year. Note that the standard deviation calculation using actual data may differ materially from Resource Capital’s standard deviation estimate. The time frames used for the standard deviation calculations were from December 31, 2009 to December 31, 2014 (Reviewed by Ashland Partners) and from January 1, 2014 to December 31, 2015 (Not Reviewed by Ashland Partners).

Sources and Description of Data

All Resource Capital performance data is supplied by FactSet Research Systems, Inc. Information is from sources deemed reliable but its accuracy cannot be guaranteed. The selected indices are not presented as appropriate benchmarks for the portfolios. The benchmarks are presented for illustrative purposes only. The performance of an index is not an exact representation of any particular investment since an investor cannot invest directly in an index.