Mark to Market The Impact of Interest Rate Changes on Portfolio Market Value John F. Grady III Managing Director February 2, 2018
Housing Market 30 year mortgage rates declined during the third quarter and remained at these low levels in the fourth quarter providing continued support for strong housing sales. Housing prices have declined from the summer peak, although this is a normal for the fall and winter months, while higher prices continue over the longer trend. Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Inflation Indicators Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Economic Growth and Inflation Third quarter GDP growth was the strongest in 3 years, and provided a 2 nd consecutive quarter of +3% growth driven primarily by consumer spending and investment and inventories. Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Yield Curve Theory
Spot Rates Spot rates are the discount rates associated with a future payment (called the arbitrage free rate). The arbitrage free valuation states that the total present value of each coupon cash flow and maturity cash flow should equal the Treasury bond itself otherwise there is an arbitrage opportunity to buy the pieces and package or buy the bond and break apart. Example 2 Year Security Price $1000 3% Coupon PV = Coup + Coup + Coup + Coup+Mat (1+R1/2)^N (1+R2/2)^N (1+R3/2)^N (1+R4/2)^N Two Year Bond Spot Rate Analysis Coupon 3% Par 1000 1,000.00 6 Months 1 Year 1.5 Years 2 Years Period 1 2 3 4 Spot Rate 0.50% 1.00% 1.50% 2.00% Cash Flow $15.00 $15.00 $15.00 $1,015.00 Discount Factor 100.3% 101.0% 102.3% 108.2% PV of Cash Flows $14.96 $14.85 $14.67 $937.70 $982.18
Pure Expectations Theory The theory explains the yield curve in terms of expected short term rates. It is an average of the expected short term rates in the future. The shape of the yield curve with this theory is based short term rate expectations of higher (normal), same (flat), lower (inverted) rates in the future A weakness is that this theory assumes investors have no preference when it comes to different maturities and the risks associated with them. 6.00% Yield Curve Scenario 5.00% 4.00% 3.00% 2.00% 1.00% 3 Month 6 Month 1 Year 2 Year 3 Year 4 Year 5 Year Normal Inverted Flat
Market Segmentation Theory The theory states that investors and borrowers have specific preferences for the issuance and purchase of bonds in various maturity ranges. Certain issuers have a short term need for debt (bank CP), and certain investors have a preference for longer term debt (pension funds). Equilibrium rates (yields) are determined by supply and demand within each maturity range. 6.00% Market Segmentation Theory S 5.00% 4.00% 3.00% S S D D 2.00% 1.00% D 3 Month 6 Month 1 Year 2 Year 3 Year 4 Year 5 Year
Fixed Income Investment Risks 9
Risks Defined Market Risk: potential for loss of principal Ability to sell at a competitive price due to supply and demand constraints Volatility in the market and time to maturity Restrictions that result in redemption penalties Call and Put Options, Security Sector, Issuer 10
Risks Defined Credit Risk: Risk of default or decline in security value due to Issuer financial conditions Arguably the biggest issue in the current environment Measures the additional return required from an investor to lend money to the institution Increases or decreases with changes in ratings Regulatory actions can also impact the risk of an issuer 11
Risks Defined Reinvestment Risk: Interest and/or Principal will be reinvested at a lower rate of return than the current interest rate Short term securities have high reinvestment risk (MMF, Discount Notes) Securities with higher coupons have higher reinvestment risk than lower coupons Mortgage Backed Securities have higher reinvestment risk Callable Securities have high reinvestment risk 12
Key Investment Program Decisions Maintain an Updated Investment Policy Consider the results of the Cash Flow Analysis Determine Risk Tolerance Determine Appropriate Target Duration Evaluate Market Conditions and Economic Data Consider Historical Perspective and the Current Environment Understand Benefits (Enhanced Earnings, Dynamic Management Approach) and Risks involved with various Investment Strategies (Liquidity, Reinvestment, Credit) Assess the relative value of each maturity and sector Implement an Active and/or Passive Strategy for Core and Liquidity Funds based on Investment Management Goals and Objectives 13
Duration and Convexity 1 4
Duration Duration is used to estimate a bond s (portfolio s) sensitivity to interest rate risk. Specifically, duration measures a bond s change in value for a given change in interest rates. Modified Duration utilizes Yield to Maturity Effective Duration factors in convexity, utilizes YTM and accounts for the value of embedded options Duration is higher (other characteristics constant) for bonds with lower market yields for bonds with lower coupons for bonds with longer maturities 1 5
Duration Duration is used to estimate a bond s (portfolio s) sensitivity to interest rate risk. Specifically, duration measures a bond s change in value for a given change in interest rates. Modified Duration utilizes Yield to Maturity Effective Duration factors in convexity, utilizes YTM and accounts for the value of embedded options Duration is higher (other characteristics constant) for bonds with higher market yields for bonds with higher coupons for bonds with longer maturities Effective Duration = Price w/ Yield Decline Price w/yield Increase 2 X Initial Price X Change in Yield
Duration Other bond characteristics equal, as yields increase, the duration of a bond will decrease As Coupons increase, the duration of a bond will decrease Duration Analysis Par/Premium/Discount Bond 2 Year Maturity Duration Analysis Par/Premium/Discount Bond 5 Year Maturity Duration 1.96 1.95 1.94 1.93 1.92 1.91 Duration 4.80 4.70 4.60 4.50 4.40 4.30 1.90 3.00% 4.00% 5.00% 6.00% 7.00% 4.20 3.00% 4.00% 5.00% 6.00% 7.00% Prem/Disc Duration 2YR Par Duration 2Yr Prem/Disc Duration 5YR Par Duration 5Yr Source: Public Trust. For informational purposes only.
Interest Rate Change and Convexity The price/yield curve is not linear for an option free bond Price 1,500 1,400 1,300 1,200 1,100 1,000 900 800 700 600 500 1,448.74 1,145.96 1,060.00 Price Change/Yield Curve Multiple YTM Scenario 2Yr, 5Yr and 20Yr Bond (3.00%) (2.00%) (1.00%) - 1.00% 2.00% 3.00% Change in Yield 944.24 875.25 723.98 Dollar Change from Par Yld Change 2 Year 5 Year 20 year (3.00%) 60.00 145.96 448.74 (2.00%) 39.50 94.71 273.55 (1.00%) 19.51 46.11 125.51 1.00% (19.04) (43.76) (106.78) 2.00% (37.62) (85.30) (197.93) 3.00% (55.76) (124.75) (276.02) Percentage Change from Par Yld Change 2 Year 5 Year 20 year (3.00%) 6.00% 14.60% 44.87% (2.00%) 3.95% 9.47% 27.36% (1.00%) 1.95% 4.61% 12.55% 1.00% (1.90%) (4.38%) (10.68%) 2.00% (3.76%) (8.53%) (19.79%) 3.00% (5.58%) (12.47%) (27.60%) Source: Public Trust. For informational purposes only.
Convexity and Option Bonds Negative convexity is present for bonds with embedded options 1,500 1,400 1,300 1,200 1,448.74 Price Change/Yield Curve Multiple YTM Scenario 2Yr, 5Yr and 20Yr Bond Positive Convexity Price 1,100 1,000 900 Negative Convexity 800 700 723.98 600 500 (3.00%) (2.00%) (1.00%) - 1.00% 2.00% 3.00% Change in Yield Source: Public Trust. For informational purposes only.
Total Return and Yield to Maturity
Yield to Maturity vs. Total Return YTM is a bond s internal rate of return based on the bond s projected cash flows, and price. Assumes all coupon payments are reinvested at the YTM. YTM at Market YTM at Book YTM to Call Total return is the return of the bond (or portfolio) since settlement. This includes income earned, realized gains and losses and the change in market value. Total Return Yield to Maturity 2 1
Total Return Converts the HPY into an annualized 360 day yield for money market rate comparison For measuring performance total return is the actual rate of return of an investment or a pool of investments over a certain period. Total return includes Interest Recognized gains/losses Unrecognized gains/losses Total Return = (1+HPY)*(1+HPY)*(1+HPY)*(1+HPY) 1
Yield to Maturity YTM is a bond s internal rate of return based on the bond s projected cash flows, and price. Assumes all coupon payments are reinvested at the YTM. Same Components as Present Value Calculation Settlement Date (Calc begins at settlement not trade date) Maturity Date Yield Coupon Frequency (annual/semi-annual/zero coupon/discount) Day Count Basis (UST vs Corp/Discount vs. Coupon) Price (Par/Discount Bond/Premium Bond) 2 3
Historical Performance and Yield Curve Analysis
Yield Curve Brexit through Post Election 3.00% US Treasury Yields 3 Months - 5 Years Maturity Yield 2.50% 2.00% 1.50% 1 Year 0.84% 2 Year 1.21% 3 Year 1.52% 4 Year 1.76% 5 Year 1.96% 0.88% 0.94% 1.00% 6 Month 0.77% 0.63% 0.59% 1.01% 0.88% 0.50% 0.31% 0.35% 0.75% 0.32% 0.49% 0.62% 0.00% Jul-15 Aug-16 Sep-17 Oct-18 Nov-19 Change July 1, 2016 December 30, 2016 Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Yield Curve July 1, 2016 vs. December 2017 Federal Funds rate increases and decreasing inflationary measures have resulted in a flatter yield curve. Yield 3.00% 2.50% 2.00% 1.50% 6 Month 1.53% 1 Year 1.72% US Treasury Yields 3 Months - 5 Years Maturity 2 Year 1.92% 3 Year 2.01% 4 Year 2.11% 5 Year 2.20% 1.20% 1.23% 1.30% 1.26% 1.23% 1.19% 1.00% 1.01% 0.88% 0.50% 0.75% 0.32% 0.49% 0.62% 0.00% Jul-15 Aug-16 Sep-17 Oct-18 Nov-19 Change July 1, 2016 December 29, 2017 Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Historical Yield Comparison 3M, 2Yr and 5Yr Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Historical Yield Comparison 3M vs 2Yr Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Historical Yield Comparison 2Yr vs 5Yr Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Income and Total Return In periods of rising interest rates, such as the period of May 2004 June 2006, longer term strategies may experience lower total return, but the income component may provide additional income versus short term investments. Price return volatility may be managed by limiting realized losses during the period. The chart shown below presents total return for various investment strategies and the components of income return and price return. Source: Bloomberg The charts above represent Bank of America Merrill Lynch index data available from Bloomberg and are intended for informational purposes only and not a recommendation. Past performance is not indicative of future performance.
Total Return Rising Interest Rate Environment 4.00% 2.00% 0.00% (2.00%) (4.00%) Annualized Return July 1, 2016 - December 31, 2017 0.69% 0.69% 0.77% 0.45% 0.00% (0.32%) (1.71%) 1.73% 1.89% 0.02% (2.18%) (0.29%) 3M T-Bill 12M T-Bill 1-3Y Corp/Gov 1-5Y Corp/Gov Price Return Income Return Total Return Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Total Return 10 Year History 4.00% Annualized Return Ten Years Ended December 31, 2017 2.00% 0.00% 0.39% 0.39% 0.00% (0.18%) 1.08% 0.90% (0.57%) 2.15% 1.59% 2.36% (0.24%) 2.12% (2.00%) 3M T-Bill 12M T-Bill 1-3Y Corp/Gov 1-5Y Corp/Gov Price Return Income Return Total Return Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Historical Performance Long Term vs Short Term Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Earnings Growth Scenario Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Historical Performance Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Annual Total Return Duration Comparison Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Annual Total Return Duration Comparison Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Annual Total Return Duration Comparison Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Rolling Annual Returns Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Quarterly Returns Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Historical Performance Historically, longer term duration investment strategies have provided higher annual returns over longer investment horizons, although with more volatility. Annual Return Index Comparison One Year and Ten Year Periods as of December 31, 2017 2.50% 2.00% One Year Annual Return Ten Year Annual Return # of Negative Quarters of 40 2.04% 2.12% 40 36 32 Annual Return 1.50% 1.00% 0.50% 0.00% 0.86% 0.39% 0 0.57% 0.90% 5 0.44% 1.51% 3 Mnth Tbill 12 Mnth Tbill 1-3 Yr UST/Agy 8 7 1.59% 0.55% 0.66% 1-3 Yr AA-AAA Corp/Gov 0.79% 10 9 1-5 UST/AGY 1-5Yr AA-AAA Corp/Gov 28 24 20 16 12 8 4 - Negative Quarters Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Projected Interest Rates Current projections indicate higher rates with a flatter yield curve. 3.00% 2.50% 2.00% 1.50% 1.00% 0.50% 0.00% Source: Bloomberg 1.53% 1.55% 1.56% 1.56% 0.99% 1.06% Forward Yield Curve Chart - January 2018 U.S. Treasury Actives 1.95% 1.97% 1.99% 2.01% 1.15% 1.24% 2.24% 1.78% 1.40% 2.32% 2.01% 1.61% 2.55% 2.28% 1.95% 0.54% 0.49% 0.41% 0.32% 0.38% 0.40% 0.33% 1Mo 3Mo 6Mo 1Yr 2Yr 3Yr 5Yr Proj. 1 Year Forward Current 1YR FWD 2YR FWD Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Fed Funds Futures Contracts Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Portfolio Characteristics
Investment Decisions Flat Yield Curve Scenario 1 Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Investment Decisions Flat Yield Curve Scenario 2 Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Investment Decisions Flat Yield Curve Scenario 1 Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Investment Decisions Flat Yield Curve Scenario 2 Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Mark to Market 1-3 Year Scenario Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Mark to Market 1-5 Year Scenario Source: Bloomberg Benchmarks are provided for illustrative purposes only. Comparisons to benchmarks have limitations because benchmarks have volatility and other material characteristics that may differ from the portfolio. Also, performance results for benchmarks do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Enhanced Cash Sample Portfolio Sample portfolios are provided for illustrative purposes only. Comparisons to actual portfolios benchmarks have limitations because portfolios have volatility and other material characteristics that may differ from another portfolio. Also, performance results for benchmarks and/or portfolios do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
1-3 Year Sample Portfolio Sample portfolios are provided for illustrative purposes only. Comparisons to actual portfolios benchmarks have limitations because portfolios have volatility and other material characteristics that may differ from another portfolio. Also, performance results for benchmarks and/or portfolios do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
1-5 Year Sample Portfolio Sample portfolios are provided for illustrative purposes only. Comparisons to actual portfolios benchmarks have limitations because portfolios have volatility and other material characteristics that may differ from another portfolio. Also, performance results for benchmarks and/or portfolios do not reflect payment of investment management/incentive fees and other fund expenses. Because of these differences, benchmarks should not be relied upon as an accurate measure of comparison.
Disclosures This presentation is for informational purposes only. All information is assumed to be correct but the accuracy has not been confirmed and therefore is not guaranteed to be correct. Information is obtained from third party sources that may or may not be verified. The information presented should not be used in making any investment decisions and is not a recommendation to buy, sell, implement or change any securities or investment strategy, function or process. Any financial and/or investment decision should be made only after considerable research, consideration and involvement with an experienced professional engaged for the specific purpose. All comments and discussion presented are purely based on opinion and assumptions, not fact, and these assumptions may or may not be correct based on foreseen and unforeseen events. All calculations and results presented and are for discussion purposes only and should not be used for making calculations and/or decisions. The data in this presentation is unaudited. Performance comparisons will be affected by changes in interest rates. Investment returns fluctuate due to changes in market conditions. Investment involves risk, including the possible loss of principal. No assurance can be given that the performance objectives of a given strategy will be achieved. Past performance is not an indicator of future performance or results. Any financial and/or investment decision may incur losses. The investment advisor providing these services is Public Trust Advisors, LLC, an investment adviser registered with the U.S. Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940, as amended. Registration with the SEC does not imply a certain level of skill or training. Public Trust is required to maintain a written disclosure brochure of our background and business experience. If you would like to receive a copy of our current disclosure brochure, privacy policy, or code of ethics please contact us.