Disclosure Concerning Investment Advice Provided to Retirement Investors Including IRAs and Assets Held in ERISA-Covered Plans (The DOL Rule)

Transition Disclosure

This disclosure is provided to you in connection with investment advice provided to you in connection with assets held in an IRA, Roth IRA, Archer Medical Savings Account, a Plan covered by Title I of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), or a plan described in Section 4975(e)(1)(A) of the Internal Revenue Code (“Code”). This disclosure may supplement other agreement(s) we have entered into with you in connection with your account(s) (“Account”) including, without limitation, any insurance or annuity contract or application, account opening agreement, investment program agreement or similar document.

References in this disclosure to “you” refer to the beneficial owner of an IRA, Roth IRA, Archer Medical Savings Account, or a participant in a Plan subject to ERISA, or a Retail Fiduciary of a Plan or IRA (or a Roth IRA). References to “us” or “we” refer to JA Glynn Investments LLC (“Financial Institution”) and references to your “Advisor” refer to the individual Advisor whose name appears above, and any other Advisor who we may from time to time assign to your Account. Capitalized terms contained in this disclosure shall have the meanings assigned in Section 5 except where otherwise defined.

This disclosure includes information that is required to be provided to you by the U.S. Department of Labor’s Best Interest Contract Exemption, 81 Fed. Reg. 21002 (April 8, 2016) (“Best Interest Contract Exemption”). That exemption permits your Advisor, us, our Affiliates and Related Entities to receive compensation for services in connection with recommendations that we or your Advisor may from time to time make to you concerning the purchase, sale or holding of investments for your Account, including any related rollover or distribution recommendations, recommendations on investment policies or strategies, portfolio composition, the selection of other persons to provide investment advice or investment management services, or the selection of investment account arrangements (e.g., brokerage or advisory), without violating the prohibited transaction provisions under ERISA that might otherwise apply.

This disclosure is effective only with respect to investment recommendations described in Section 2 that we or your Advisor may provide during the period of June 9, 2017 through July 1, 2019.

In no event will this disclosure apply to investment recommendations we or your Advisor may provide prior to this period.

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