Description of Matson Money, Inc.

This content is not to be considered investment advice and is not to be relied upon as the basis for entering into any transaction or advisory relationship or making any investment decision.

Matson Money, Inc. “Matson” is a federally registered investment advisor with the Securities Exchange Commission (“SEC”) and has been in business since 1991. In Canada, Matson is registered as a portfolio manager in Ontario, Alberta, and British Columbia.  Registration with the SEC and the Canadian securities regulatory authorities does not imply their approval or endorsement of any services provided by Matson. This content is based on the views of Matson.  The concepts discussed herein are for educational purposes only. This content includes the opinions, beliefs, or viewpoints of Matson Money and its Co-Advisors and should not be relied upon for entering into any transaction, advisory relationship, or making any investment decision.  Other organizations or persons may analyze investments and the approach to investing from a different perspective than that reflected in this content.  Nothing included herein is intended to infer that the approach to investing discussed in this content will assure any particular investment result.

All of Matson Money’s advisory services are marketed almost exclusively by either Solicitors or Co-Advisors (“Promoters”).  The term “Co-Advisor” is equivalent in meaning to the term “Promoter.” Co-Advisors are either unaffiliated separately registered investment advisors, or registered representatives and/or investment advisor representatives of unaffiliated dual registrant brokerage firms.  Matson is not affiliated with the Co-Advisors or the firms with which they are associated.  Each Co-Advisor enters into a contractual agreement to serve as a non-discretionary Co-Advisor with respect to clients referred by the Co-Advisor to Matson.  Solicitors typically do not enter into investment management agreement with clients.  Both Co-Advisors and Solicitors have similar responsibilities including promoting and referring clients, and client coaching, including maintaining suitability information, routine service issues, and relationship management.  All Co-Advisors are independent contractors, not employees or agents of Matson.  Co-Advisors are paid fees as set forth under the tri-party Investment Management Agreement.   Such fees are negotiable and may range from .20% to 1.2% of Account Owner assets under management. Matson does not retain any portion of these fees and is compensated only through advisory fees embedded in the Matson Funds.

The Co-Advisor receives an annual fee, paid quarterly in advance by Matson, based on total assets under management of the Co-Advisor’s clients. Generally, the greater the assets under management that the Co-Advisor’s clients have, the higher their annual compensation will be. Due to this compensation arrangement, the Co-Advisor has a financial incentive to promote Matson in lieu of other financial services providers, which results in a material conflict of interest.

Account Owners referred by other Co-Advisors may pay lower advisory fees for comparable services as a result of the range of fees available at each asset level breakpoint.

Co-Advisor’s fee may be paid directly by Account Owner to Co-Advisor or this fee may be deducted from Account Owner’s account by Matson and paid by Matson to Co-Advisor.  No part of this fee is retained by Matson. The Co-Advisor's relationship with Matson, including fees payable from the Account Owner’s Account, is governed by a separate agreement between Matson and the Co-Advisor. The nature of this relationship creates an inherent conflict of interest.

Additionally, Co-Advisors who have entered into a Co-Advisory Agreement with Matson Money can also choose to enroll in the Matson Money Brand Ambassador program under an additional separate Brand Ambassador Agreement with Matson Money. A Brand Ambassador can use Matson’s Licensed Marks in connection with the operation of its business as an investment advisor, and Matson grants the Brand Ambassador a license to use the Licensed Marks, subject to the terms and conditions of the Agreement. In addition, the Brand Ambassador retains Matson to provide certain operational consulting services in connection with the Brand Ambassador’s business operations and use of the Licensed Marks, and provides such Operational Consulting Services which includes additional training and coaching, subject to the terms and conditions of the Agreement. Matson Money receives compensation for the Brand Ambassador arrangement of approximately $100,000 to cover the cost of creating branded assets like films, presentations, logos, and other various marketing material, as well as additional services like in-depth training and coaching for leading the American Dream Experience. Some additional expenses can be charged for additional services.

In Canada, Matson acts as a sub-advisor to another registered portfolio manager (“Advisor”).  Matson is not affiliated with the Advisor.  The Advisor and Matson have entered into a sub-advisory agreement, under which Matson has agreed to sub-advise client accounts managed by the Advisor.  Client accounts are invested in strategies managed by Matson. The Advisor is responsible for client onboarding and account opening collection of know-your-client information and suitability determination and overall client relationship management.

All investing involves risks and costs.  These risks may not always be mitigated through long-term investing or diversification.  Your advisor can provide you with more information about the risks and costs associated with specific programs.  Your advisor is not affiliated with Matson Money, Inc. The information contained in this content is for educational purposes only and is not intended as investment advice. No investment strategy (including asset allocation and diversification strategies) can ensure peace of mind, guarantee profit, or protect against loss.

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