INVESTMENT PROFESSIONALS, INC.

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1 INVESTMENT PROFESSIONALS, INC. Part 2A Appendix 1 Advisor Managed Choice Wrap Program Brochure San Pedro Avenue Suite 300 San Antonio, TX March 30, 2017 This wrap fee program brochure provides information about the qualifications and business practices of Investment Professionals, Inc. If you have any questions about the contents of this brochure, please contact us at (210) The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Investment Professionals, Inc. is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information you may use to determine to hire or retain an Adviser. Additional information about the Investment Professionals, Inc. is also available on the SEC s website at: 1

2 Item 2 - Summary of Material Changes This Brochure dated March 30, 2017 is a new brochure that provides information pertaining to IPI s wrap fee program, Advisor Managed Choice. Please review this brochure for information about your account including changes to the option, margin, check writing features, unsupervised assets, account restrictions, short term trading restrictions, and fees. We will provide you with a new wrap fee program brochure, at any time, without charge. Currently, our wrap fee program brochure may be requested by contacting IPI at (800) and is available on our web site ( under the Disclosures section, free of charge. 2

3 Item 3 - Table of Contents Item 2 - Summary of Material Changes... 2 Item 3 - Table of Contents... 3 Item 4 - Services, s & Compensation... 4 Account Opening... 7 Options Trading... 7 Margin, Check Writing, and Debit Cards... 8 Unsupervised Assets... 8 Account Restrictions... 8 Concentrated Positions... 9 Short Term Trading Restrictions... 9 Initial Public Offerings... 9 Item 5 - Advisory s, Transaction s, and Account Minimums Advisor Managed Choice I (Rep as PM) Advisor Managed Choice II (Rep as PM) Advisor Managed Choice III (Rep as PM) Unified Managed Account UMAv2 (Rep as PM) Account Level s Account Minimum Requirements and Types of Clients Portfolio Manager Selection and Evaluation Client Information Provided to Portfolio Managers Client Contact with Portfolio Managers Additional Information

4 Item 4 - Services, s & Compensation Advisor Managed Choice ( the Program ) is a non-discretionary investment advisory program sponsored by Investment Professionals, Inc, ( IPI or the Adviser ). This brochure contains important information relating to the Program including client responsibilities for their Program Accounts and other matters relevant to a decision whether to participate in the Program. You should read this brochure carefully prior to deciding whether the Program is appropriate for you and ask your IPI Investment Advisory Representative any questions that you may have. The Program has been designed to give you the flexibility to use your account as you deem appropriate within certain prescribed limits involving asset allocation, security selection, concentration, and other factors. Although your IPI Investment Advisory Representative will furnish you with investment advice and guidance, all purchases and sales of securities in your account will take place only upon your specific instruction. You assume the full responsibility for all trading decisions you make, including risk of loss. The Advisor Managed Choice options are Non-Discretionary Rep as Portfolio Manager (Rep as PM) portfolios. Non-Discretionary means that you, the client, must approve all changes and trading within the portfolios. IPI offers the Program through Envestnet Portfolio Solutions (EPS) a third party independent registered investment adviser. Upon enrollment in the Program, IPI opens an account in your name at Pershing, LLC, (Pershing) a third-party broker/dealer which is a subsidiary of the Bank of New York/Mellon Corporation. Pershing is located at One Pershing Square, Jersey City, New Jersey Pershing provides custody, trade execution, clearing, and other brokerage-related services for Advisor Managed Choice accounts. There are four versions of the Program, known as Advisor Managed Choice I (Rep as PM), Advisor Managed Choice II (Rep as PM), Advisor Managed Choice III (Rep as PM), and Unified Managed Account (UMAv2) (Rep as PM). Advisor Managed Choice I (Rep as PM) and Advisor Managed Choice II (Rep as PM) Program Accounts may contain individual equities and bonds, unit investment trusts, open and closed end mutual funds, Exchange Traded Funds (ETFs), Exchange Traded Notes (ETNs) Traded Real Estate Investment Trusts (REITs), (throughout the remainder of this document, any reference to Real Estate Investment Trusts (REITs) shall be considered to mean Traded REITs ) and other securities that may be suitable for you. Advisor Managed Choice III (Rep as PM) Program Accounts may contain only mutual funds. The Unified Managed Account UMAv2 (Rep as PM) allows advisors to build customized portfolio models using a wide variety of asset classes and to manage multiple client accounts following each model. This investment strategy delivers the benefits of combining traditional separately managed accounts, mutual funds, and ETFs in a single fully diversified portfolio. 4

5 In all programs, your IPI Investment Advisory Representative creates and manages the asset allocation model for you. There are three types of fees charged; Advisor, Sponsor, and Transaction. The Advisor is paid to your IPI Investment Advisory Representative for providing investment advice to you and can be negotiated. The Sponsor and the Transaction compensates IPI, EPS, and Pershing for the services provided to your Program Account, including use of the EPS platform, trading, and custodial services. The account minimums and fee characteristics are: Program Advisor Sponsor Transaction Account Minimum Advisor Managed Choice I (Rep as PM) Yes Yes No $100,000 Advisor Managed Choice II (Rep as PM) Yes Yes Yes $35,000 Advisor Managed Choice III (Rep as PM) Yes Yes No $10,000 Unified Managed Account (UMAv2) (Rep as PM) Yes Yes No $150,000 Before investing in the Program, your IPI Investment Advisory Representative and you will compile pertinent financial and demographic information to develop an investment program that will meet your goals and objectives. Your IPI Investment Advisory Representative, through EPS, will use a number of proprietary analytical tools and commercially available optimization software applications to develop an asset allocation strategy. Among the factors considered in designing a strategy are historical rates of risk and return for various asset classes, correlation across asset classes and risk premiums. For Advisor Managed Choice I (Rep as PM) and Advisor Managed Choice II (Rep as PM) Program Accounts, your IPI Investment Advisory Representative will furnish you with investment advice and guidance and recommend a portfolio of equities, options, fixed income, open and closed end mutual funds, unit investment trusts, real estate investment trusts, exchange traded funds, and other securities that we deem appropriate to meet your specific investment goals and objectives, risk tolerance, time horizon, and other pertinent factors. Mutual Funds shall be purchased on a no load or a load waived basis through Pershing. For Advisor Managed Choice III (Rep as PM) accounts, your IPI Investment Advisory Representative will furnish you with investment advice and guidance and recommend a portfolio of open end mutual funds that we deem appropriate to meet your specific investment goals and objectives, risk tolerance, time horizon, and other pertinent factors. Mutual Funds shall be purchased on a no load or a load 5

6 waived basis through Pershing. For Unified Managed Account UMAv2 (Rep as PM) Program Accounts, your IPI Investment Advisory Representative will furnish you with investment advice and guidance and recommend a portfolio combining traditional separately managed accounts, mutual funds, and ETFs in a single fully-diversified portfolio deemed appropriate to meet your specific investment goals and objectives, risk tolerance, time horizon, and other pertinent factors. Mutual Funds shall be purchased on a no load or a load waived basis through Pershing. The UMAv2 allows advisors to build customized portfolio models using a wide variety of asset classes and to manage multiple client accounts following each model. For certain investments, such as mutual funds, you will receive a prospectus or other disclosure documents relating to the investment. You should read these documents carefully because they contain important information about the risks, liquidity, fees, expenses, conflicts of interest, and other material considerations associated with those investments. As you review these materials, you should consider your ability to bear the risks associated with those investments before making any decision to invest. Because the Program is a non-discretionary investment advisory program, it is solely your responsibility to determine whether to follow any advice or recommendations made by your IPI Investment Advisory Representative and transactions for your account will take place only upon your instructions to proceed. 6

7 The following are features of your Program Account: Account Opening Program accounts may be opened and held only by investors residing in the 50 United States, the District of Columbia, or Puerto Rico. You may also open and hold a Program Account if you are in the U. S. military or are a military dependent residing outside of the United States with an Army Post Office (APO) or Fleet Post Office (FPO) address. If you are a United States resident at the time you open a Program account and move outside of the United States, other than to an APO or FPO address, IPI reserves the right to sell all of the securities in your account, send the proceeds to you at your address of record, and close your account at any time. Upon opening a Program account, you agree to deposit cash or readily marketable securities with a market value of at least the minimum amount required to open a Program Account. We will liquidate any securities that you deposit, transfer or contribute into your Program Account that do not comprise a portion of your investment model. Mutual funds shares that are transferred into and sold in your Program Account may be subject to sales load, redemption fees or other applicable charges imposed by the funds. You may incur and will be responsible for any tax liabilities resulting from the ownership and sale of such securities. We will not charge a separate brokerage commission or transaction fee in connection with these sales. We will charge you any transaction or other fees associated with selling securities that are not traded in the United States. IPI or the Custodian reserve the right to reject any securities that you deposit, transfer, or contribute into your Program Account for any reason or to require that you transfer such securities to a self-directed brokerage account outside the Program. Options Trading If your Program Account does not have open option positions as of April 1, 2017, only the selling and repurchase of covered call options against a long stock position held in those Program Accounts is permitted in order to generate income and to establish a partial hedge against a decline in the price of the long stock position. No other option strategies such as purchasing or selling puts, spreads, or straddles are permitted in any other Program Account unless otherwise agreed to in writing by IPI and you. If your Program Account does have open option positions other than covered calls against long stock positions in that Program Account, you may continue to trade options with the express consent of IPI. In order to participate in the covered call writing strategy, you must meet certain criteria, complete the forms required by IPI in its sole discretion, and be approved by IPI. IPI reserves the right to revoke its approval for you to sell and repurchase covered calls in any Program Account at any time for any reason. The use of options is not suitable for all investors and that you should be aware that the use of options involves additional risks which are described in the booklet Characteristics and Risks of Standard Options (disclosure document), published by the Chicago Board Options Exchange. A copy of the disclosure document will be provided to you as part of the approval process. 7

8 If you are interested in the selling of covered calls, consult your IPI Investment Advisory Representative for further information. Margin, Check Writing, and Debit Cards IPI will discontinue the use of margin in all Program Accounts with the exception of those Program Accounts with a margin debit balance as of the close of business on March 31, Those clients with Program Accounts with a margin debit balance as of March 31, 2017, may continue to trade using margin with the express consent of IPI. As of April 14, 2017, check writing and debit cards will not be available on any Program Account. Unsupervised Assets Upon account opening you may leave certain securities in a Program Account over which neither IPI nor the Investment Advisor Representative has been given discretionary trading authority (Unsupervised Assets). IPI or the Investment Advisory Representative may request that you confirm the identity and quantity of any Unsupervised Assets in writing. Neither IPI, your Investment Advisory Representative will provide any investment advisory services of any kind with respect to Unsupervised Assets. Neither IPI nor your Investment Advisory Representative will have any duty responsibility, or liability with respect to the Unsupervised Assets and will not consider the Unsupervised Assets when managing the portion of the account for which it provides investment advice. The market value of Unsupervised Assets will not be considered when calculating account performance or management fees. No additional purchases of Unsupervised Assets will be permitted in a Program Account. IPI reserves the right to request that you transfer any or all Unsupervised Assets to a self-directed brokerage account at any time for any reason. Account Restrictions You may place reasonable restrictions on the management of your Program Account and may, at any time, modify any reasonable restrictions that are in place. Any reasonable restriction that you may wish to impose must be requested in writing and is subject to our review and approval in our sole discretion. We will not accept any restrictions that are inconsistent with the Program s stated investment strategy or philosophy or are inconsistent with the nature or operation of the Program. Further, restrictions on the underlying holdings of a mutual fund or ETF will not be considered reasonable under the Program. If we determine that a restriction request is reasonable and therefore, accept a restriction on your Program Account, you acknowledge and understand that the performance of Program Accounts with restrictions imposed will differ from, and may be lower than, the performance of similar unrestricted Program Accounts. IPI and our affiliates, employees, and agents shall not be liable to you or any other person for any investment made in violation of any restriction or guideline that was not submitted or confirmed in writing and accepted by us. 8

9 Concentrated Positions A concentrated position (whether in a particular security, industry, sector, geographic region, or otherwise, can be expected to increase the risk and volatility of your Program Account. If you assemble a concentrated position in your Program Account, and thereby reduce diversification, you can assume the risk of incurring substantial loss in the value of the entire Program Account if there is a decline in the value of the concentrated position. Short Term Trading Restrictions Your Program Account is not intended for day trading or other active trading activity, including active trading in mutual funds based upon market timing. Excessive trading of mutual fund shares can harm existing fund shareholders. Therefore, many mutual fund companies have adopted restrictions against excessive trading such as imposing fees for excessive trading or prohibiting trading of mutual fund shares for periods of time. You should read the prospectuses of the mutual funds purchased in your Program Account for information about any short-term restrictions. Initial Public Offerings Advisor Managed Choice Program Accounts do not participate in equity initial public offerings. 9

10 Item 5 - Advisory s, Transaction s, and Account Minimums Advisor Managed Choice I (Rep as PM) The minimum amount of cash or securities to open a Advisor Managed Choice I (Rep as PM) account is $100,000. You will be charged an advisory fee for the management of your Program Account. This advisory fee covers services which include portfolio construction, asset allocation, the ongoing review, at least annually, of your Program Account and certain brokerage related services. The advisory fee is charged quarterly in advance based upon the average daily market value of the assets in your Program Account during the previous calendar quarter. The market value of assets designated by you as Unsupervised Assets (as defined in the Services, s & Compensation section of this brochure) will not be included in the average daily market value calculation. The advisory fee has two components; a Sponsor and an Advisor. The Sponsor compensates IPI, EPS, and Pershing for the services provided to your Program Account, including use of the EPS platform, trading, and custodial services. The Advisor is paid to your IPI Investment Advisory Representative for providing investment advice to you and may be negotiated. The advisory fee charged to your Program Account does not cover charges resulting from SEC fees, electronic fund and wire transfer fees, and miscellaneous charges. It does not include fees charged by mutual fund companies to manage mutual funds held in your Program Account. You may obtain a schedule of these miscellaneous charges from your IPI Investment Advisory Representative. Please refer to the mutual fund prospectus of each mutual fund for fees charged by the mutual fund company. The PAM Schedule breaks down all of the advisory fee ranges at each of the different breakpoints available on the PAM Platform. Note: The Pershing Annual Maintenance will apply to all PAM accounts. Traditional, SEP, Roth IRAs= $43.50; SIMPLE/QRP plans= $50. For Mutual Fund Only accounts, please establish them as MF Only IRA to provide the reduced fee of $12. Minimum Investment $ 100,000 Program Name: Advisor Managed Choice I (Rep as PM) (All fees included) Account Size Sponsor Manager Min. Advisor Minimum Max Advisor Client fee Amount First $250, % N/A 0.50% 0.95% 2.75% Next $250, % N/A 0.50% 0.90% 2.50% Next $500, % N/A 0.50% 0.85% 2.25% Next $1,000, % N/A 0.50% 0.80% 2.00% Over $2,000, % N/A 0.50% 0.70% 1.75% 10

11 Advisor Managed Choice II (Rep as PM) The minimum amount of cash or securities to open a Advisor Managed Choice II (Rep as PM) account is $35,000. You will be charged an advisory fee for the management of your Program Account. You will also be charged a transaction fee for each trade in your Program Account. The advisory fee and transaction fee cover services which include portfolio construction, asset allocation, the ongoing review of your Program Account and certain brokerage related services. The advisory fee is charged quarterly in advance based upon the average daily market value of the assets in your Program Account during the previous calendar quarter. The market value of assets designated by you as Unsupervised Assets (as defined in the Services, s & Compensation section of this brochure) will not be included in the average daily market value calculation. The advisory fee has two components; a Sponsor and an Advisor. The Sponsor compensates IPI, EPS, and Pershing for the services provided to your Program Account, including use of the EPS platform, trading, and custodial services. The Advisor is paid to your IPI Investment Advisory Representative for providing investment advice to you and may be negotiated. The advisory fee charged to your Program Account does not cover charges resulting from SEC fees, electronic fund and wire transfer fees, and miscellaneous charges. It does not include fees charged by mutual fund companies to manage mutual funds held in your Program Account. You may obtain a schedule of these miscellaneous charges from your IPI Investment Advisory Representative. Please refer to the mutual fund prospectus of each mutual fund for fees charged by the mutual fund company. Program Name: Advisor Managed Choice II (Rep as PM) (Client pays ticket charges) Account Size Sponsor Manager Minimum Investment Minimum Platform : Min. Advisor Minimum Client $35,000 $75 Max fee Amount First $250, % N/A 0.50% 0.80% 2.75% Next $250, % N/A 0.50% 0.75% 2.50% Next $500, % N/A 0.50% 0.70% 2.25% Next $1,000, % N/A 0.50% 0.65% 2.00% Over $2,000, % N/A 0.50% 0.62% 1.75% The transaction fee is $ per trade of 1-1,000 shares and $ plus $ per share for trades of 1,000+ shares. Example Sell order for 2,000 shares would generate a $45.00 transaction fee. 2,000 X.015 = $30.00 (+ $15.00) = $

12 Advisor Managed Choice III (Rep as PM) The minimum amount of cash or securities to open an Advisor Managed Choice III (Rep as PM) account is $10,000. You will be charged an advisory fee for the management of your Program Account. This advisory fee covers services which include portfolio construction, asset allocation, the ongoing review of your Program Account and certain brokerage related services. The advisory fee is charged quarterly in advance based upon the average daily market value of the assets in your Program Account during the previous calendar quarter. The market value of assets designated by you as Unsupervised Assets (as defined in the Services, s & Compensation section of this brochure) will not be included in the average daily market value calculation. The advisory fee has two components; a Sponsor and an Advisor. The Sponsor compensates IPI, EPS, and Pershing for the services provided to your Program Account, including use of the EPS platform, trading, and custodial services. The Advisor is paid to your IPI Investment Advisory Representative for providing investment advice to you and may be negotiated. The advisory fee charged to your Program Account does not cover charges resulting from SEC fees, electronic fund and wire transfer fees, and miscellaneous charges. It does not include fees charged by mutual fund companies to manage mutual funds held in your Program Account. You may obtain a schedule of these miscellaneous charges from your IPI Investment Advisory Representative. Please refer to the mutual fund prospectus of each mutual fund for fees charged by the mutual fund company. Program Name: Advisor Managed Choice III (Rep as PM) Account Size Sponsor Manager 12 Minimum Investment $10,000 Minimum Platform : $75 (Client % adjusts automatically in the PAM System) Min. Advisor Minimum Client Max fee Amount First $250, % N/A 0.50% 0.60% 2.75% Next $250, % N/A 0.50% 0.60% 2.50% Next $500, % N/A 0.50% 0.60% 2.25% Next $1,000, % N/A 0.50% 0.60% 2.00% Over $2,000, % N/A 0.50% 0.60% 1.75% The cost of investment advisory services provided through the Program may be more or less than the cost of purchasing similar services separately. For example, if there is active trading in your Program Account the advisory fee may cost you less than if you purchased advisory and custodial services separately and were charged brokerage commissions for each trade. Conversely, if there is little trading in your Program Account, the advisory fee may cost you more than if you purchased advisory and custodial services separately and were charged brokerage commissions for each trade. Among the factors affecting the relative cost to you include the size of the account, the type of securities in the account (i.e., equity or fixed income, mutual funds), the trade size, and the volume of trades. Your IPI Investment Advisory Representative will receive compensation as a result of your

13 participation in the Program. The amount of the compensation may be more or less than your IPI Investment Advisory Representative would receive if you participated in other advisory programs cosponsored by IPI or if you paid separately for investment advice, brokerage, and other services. Therefore, your IPI Investment Advisory Representative may have a financial incentive to recommend the Advisor Managed Choice Program instead of other programs or services. You may group multiple Program Accounts in order to obtain lower advisory fees based upon the total amount of assets under management. For purposes of this Agreement, householding shall mean aggregating eligible Program Accounts in order to qualify for more favorable advisory fees. Eligible Program Accounts include those registered in the name of the following members of the same family: spouse, child, child s spouse, grandchild, grandchild s spouse, brother, brother-inlaw, sister, or sister-in-law. Program Accounts that are not eligible for householding include, but are not limited to corporate accounts, Keoghs, 401(k)s, 403(b)s, investment clubs, estate accounts, and partnerships. We are not responsible for identifying accounts for householding and will household accounts only upon your specific written request. We may household additional Program Accounts solely at our discretion. The assets of householded accounts are not co-mingled and retain ownership rights and responsibilities. 13

14 Unified Managed Account UMAv2 (Rep as PM) You will be charged an advisory fee for the management of your Program Account. This advisory fee covers services which include portfolio construction, asset allocation, the ongoing review of your Program Account and certain brokerage related services. The advisory fee is charged quarterly in advance based upon the average daily market value of the assets in your Program Account during the previous calendar quarter. The market value of assets designated by you as Unsupervised Assets (as defined in the Services, s & Compensation section of this brochure) will not be included in the average daily market value calculation. The advisory fee has two components; a Sponsor and an Advisor. The Sponsor compensates IPI, EPS, and Pershing for the services provided to your Program Account, including use of the EPS platform, trading, and custodial services. The Advisor is paid to your IPI Investment Advisory Representative for providing investment advice to you and may be negotiated. The advisory fee charged to your Program Account does not cover charges resulting from SEC fees, electronic fund and wire transfer fees, and miscellaneous charges. It does not include fees charged by mutual fund companies to manage mutual funds held in your Program Account. You may obtain a schedule of these miscellaneous charges from your IPI Investment Advisory Representative. Please refer to the mutual fund prospectus of each mutual fund for fees charged by the mutual fund company. Program Name: Unified Managed Account UMAv2 (Rep as PM) Minimum Investment $150,000 Account Size Sponsor Manager Min. Advisor Minimum Client Max fee Amount First $250, % Varies 0.50% 1.02% 2.75% Next $250, % Varies 0.50% 0.97% 2.50% Next $250, % Varies 0.50% 0.92% 2.25% Next $250, % Varies 0.50% 0.87% 2.00% Over $1,000, % Varies 0.50% 0.82% 1.75% 14

15 Account Level s The advisory fee charged to your Program Account does not cover charges resulting from SEC fees, electronic fund and wire transfer fees, and miscellaneous charges. It does not include fees charged by mutual fund companies to manage mutual funds held in your Program Account. You may obtain a schedule of these miscellaneous charges from your IPI Investment Advisory Representative. Please refer to the mutual fund prospectus of each mutual fund for fees charged by the mutual fund company. Additional account level fees apply. Minimum Account Level s Pershing, LLC Envestnet Minimum Annual Wrap per Account* $100 $75 *Accounts charged the minimum annual wrap fee amount may exceed the maximum annual total client fee percentage. Other Account Level s Account Activity s Inactive Account * (retail accounts only) $25 Physical Statement Surcharge * (per statement) $0 Physical Trade Confirmation Surcharge* (per trade) $0 *Note: Certain account types are excluded based on Pershing and IPI policies Cashiering Services Federal Fund Wires $25 Overnight Check $15 Overnight Check - Saturday Delivery $20 Stop Payment for Check distributions $10 Returned Check on Check deposits $30 Returned ACH on ACH deposits $30 Insufficient Funds (AMA/ Corestone) $25 Custody Direct Registration to Transfer Agent $25 Incoming DRS Transfer (charged by transfer agent) $15 Legal Security Transfer $90 Termination s Outgoing Account Transfer $100 Retirement Termination $95 Note: Retirement custodial maintenance fees may apply upon termination of account Retirement Custodial s IRA Maintenance - Multi-Product (annually) $43.50 IRA Maintenance - Mutual Fund Only (annually) $12 SIMPLE IRA fee & QRP maintenance fee (charged up front annually) $50 Multi-product IRA to Mutual Fund Only IRA Conversion $50 15

16 Account Minimum Requirements and Types of Clients The minimum amount of cash or securities to open an Advisor Managed account is as follows: Program Advisor Sponsor Transaction Account Minimum Advisor Managed Choice I (Rep as PM) Advisor Managed Choice II (Rep as PM) Advisor Managed Choice III (Rep as PM) Unified Managed Account (UMAv2) (Rep as PM) Yes Yes No $100,000 Yes Yes Yes $35,000 Yes Yes No $10,000 Yes Yes No $150,000 IPI offers Advisor Managed Choice accounts to individuals, high net worth individuals, other investment advisors, banks, and trusts. Participation in each of the Programs may carry a minimum account size for any particular portfolio and product selected. Mutual fund or ETF asset allocation portfolios will require a minimum investment of $10,000 - $25,000. Separately managed accounts for equity and fixed income strategies will require a minimum investment of at least $150,000. Portfolio Manager Selection and Evaluation Not Applicable. Client Information Provided to Portfolio Managers Personal identification (such as name, address, Social Security number, date of birth, assets and income), account and holdings data disclosed to Investment Advisory Representatives and Pershing to enable us to service the accounts. IPI and EPS only share your personal information and account data pursuant to established IPI and EPS Privacy Policies. In providing services to your Program Account, IPI and/or EPS may use third-party service providers, who are contractually bound to respect and protect the privacy of your information. IPI and EPS also receive information about your stated investment objectives, investment restrictions and investor risk rating. Your risk rating is based on your stated responses in the account opening process and classifies you as a conservative, moderate, aggressive or a speculative type of investor. 16

17 Client Contact with Portfolio Managers You may contact your IPI Investment Advisory Representative during normal business hours to discuss your account. Additional Information IPI s broker-dealer has had 15 disciplinary events since our inception in Details may be found on FINRA s BrokerCheck system or the IAPD, which can be found at: or You may access such information by searching for the Company name. If you have any questions regarding accessing the BrokerCheck or IAPD system, please contact us. Please refer to IPI s Form ADV Part 2A for information about IPI s Code of Ethics, Interest in Client Transactions, Personal Trading, Review of Accounts, Client Referrals and Compensation, and Financial Information. 17