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Disclosures

Performance Disclosure

Performance data quoted represents past performance and does not guarantee future results. The investment return and principal of an investment will fluctuate so that an investor’s shares when redeemed may be worth more or less than original cost. The values represented in this report may not reflect the true original cost of your initial investment. Performance returns for time periods longer than 365 days have been annualized. The composite has been maintained since December 2020 by utilizing Mr. Benjamin C. Halliburton’s personal Dividend Value portfolio. Prior to December 2020, the composite was maintained as explained below. Cary Street Partners (“CSP”) and Tradition Capital Management claimed compliance with the Global Investment Performance Standards (GIPS®) and has previously prepared this report in compliance with the GIPS standards. Performance shown after December 31, 2018, though believed to be accurate, has not been independently verified. In November 2020, Tradition Capital Management became Cary Street Partners Asset Management – Active Management (“CSPAM AM”). In April 2019, Tradition Capital Management became a subsidiary of Cary Street Partners Financial. Prior to July 1, 2009, the Dividend Value composite was under the management of Haven Capital Management LLC. Effective July 1, 2009, Haven Capital Management LLC joined with Tradition Capital Management, LLC. The Dividend Value Equity composite was created on April 1, 2005. Performance presented prior to July 1, 2009, occurred before Dividend Value was under the Tradition RIA. The Haven portfolio managers joined the Tradition team in managing Dividend Value at Tradition. An independent accounting firm performed an examination of this track record; an Independent Accountant’s Report is available upon request. Performance is calculated and expressed in U.S. Dollars. Total Haven assets under management on June 30, 2009 were $133MM. Composite includes accounts valued at $0.2MM or greater. The Dividend Value Equity composite is comprised of equity accounts, including cash reserves, managed in the dividend value style and for comparison purposes measured against the S&P 500 Index. Wrap accounts are included in the composite; as of 12/2012 the composite is comprised of 8% wrap assets, 12/2013 – 4%, 12/2014 – 6%, 12/2015 – 4%, 12/2016 – 4%, 12/2017 – 4%, 12/2018 – 5%, 12/2019 – 5%. Minimum account size was $200,000. Prior to 1/2007 no minimum account size was required. The S&P 500 Index returns are before taxes. The S&P 500 (a registered trademark of McGraw-Hill Companies) is an unmanaged index of common stock. Unmanaged indices are for illustrative purposes only. An investor cannot invest directly in an index. The Russell 3000 Value Index returns are before taxes. An index is for illustrative purposes only. Returns are presented gross and net of management fees. The net performance results reflect time-weighted rates of return, the re-investment of dividends and other account earnings, and are net of applicable account transaction and custodial charges, as well as Tradition’s management fee. Net fee performance was calculated assuming a 1% fee. Actual management fees may differ. In addition to a management fee, some accounts pay an all-inclusive fee based on a percentage of assets under management. Other than brokerage commissions, this fee includes portfolio monitoring, consulting services, and in some cases, custodial services. From December 2020 to present the account is Mr. Halliburton’s and is non-fee paying. Prior to January 1, 2002, one non-fee-paying account was included in this composite which represents 100% of the composite. Gross performance includes all of the aforementioned criteria except for the deduction of Tradition’s management fee. Given the use of non-fee paying employee accounts in the composite, we have assumed a 1% fee for the net performance figures for all periods. If an account has a 15% of total portfolio withdrawal/deposit, over a 2-month period, the account will be taken out of the composite at the end of the month preceding the withdrawal/deposit and will not be put back in for 3 months. On 1/1/2009, the cash flow policy changed from 15% to 25%. The annual composite dispersion is an asset-weighted standard deviation calculated when there are more than five accounts in the composite for the entire year. The firm maintains a complete list and description of composites, which are available upon request. Policies for valuing portfolios, calculating performance, and preparing compliant presentations are available upon request. The data and information necessary to support all items included in compliant presentations is captured and maintained for all years presented on the presentations. Records include custodian statements, and the transaction, position, market value and performance data prior to 2020, all information was stored in Cary Street Partners’ and Tradition Capital Management’s portfolio accounting systems. Some of this information was prepared by or obtained from third party sources believed to be reliable, but Tradition Investment Management does not guarantee the accuracy or completeness of such information. The material has been prepared or is distributed solely for information purposes and is not a solicitation or an offer to buy any security or instrument or to participate in any trading strategy. Past performance is not indicative of future results. *Informa Financial Intelligence’s proprietary performance screens, PSN Top Guns ranks products in six proprietary categories in over 50 universes. This is a well-respected quarterly ranking and is widely used by institutional asset managers and investors.

Tradition Investment Management Disclosure

Tradition Investment Management is a registered Investment Adviser – CRD# 325015. Tradition Investment Management and its representatives are in compliance with the current filing requirements imposed upon Florida State registered investment advisers and by those other states in which Tradition Investment Management maintains clients. Tradition Investment Management may only transact business in those states in which it is registered or qualifies for an exemption or exclusion from registration requirements. Tradition Investment Management’s web site is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links. Accordingly, the publication of Tradition Investment Management’s web site on the Internet should not be construed by any consumer and/or prospective client as Tradition Investment Management’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet. Any subsequent, direct communication by Tradition Investment Management with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of Tradition Investment Management, please contact the state securities regulators for those states in which Tradition Investment Management maintains registration or a notice filing. A copy of Tradition Investment Management’s current written disclosure statement discussing Tradition Investment Management’s business operations, services, and fees is available from Tradition Investment Management upon written request. Tradition Investment Management does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Tradition Investment Management web site or incorporated herein, and takes no responsibility, therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Definitions

Alpha is a risk (beta adjusted) measurement. Officially, alpha measures the difference between a portfolio’s actual returns and what it might be expected to deliver based on its level of risk. Higher risk generally means higher reward. A positive alpha means the fund has beaten expectations. A negative alpha means that the manager failed to match performance with risk. If two managers had the same return, but one had a lower beta, that manager would have a higher alpha.
Multi-Statistic Quartile Ranking Bar – The Multiple Statistics Quartile Ranking graph ranks various performance and statistics of PSN managers, market indexes or your own self-entered products against a universe. The range of returns/other modern portfolio characteristics in the universe are represented by floating bars. Each bar is broken up into 4 quartiles. The upper quartile represents the top 25% of the managers in the particular universe for the particular time period (you can choose up to eight time periods). The managers, indexes and portfolios are plotted relative to the floating bars.
The Sharpe Ratio, developed by Professor William F. Sharpe, is a measure of reward per unit of risk – the highest the Sharpe ratio, the better. It is a portfolio’s excess return over the risk-free rate divided by the portfolio’s standard deviation. The portfolio’s excess return in its geometric mean return minus the geometric mean return of the risk-free investment (by default, T-bills).
Standard Deviation is a statistical measure of volatility; indicates the “risk” associated with a return series. The Fund vs. Universe graph measures a fund’s percentile rank for a given statistic relative to the chosen category.
The Up and Down Capture is a measure of how well a manager was able to replicate or improve on phases of positive benchmark returns, and how badly the manager was affected by phases of negative benchmark returns.
Total Risk Reward is used to compare the performance and risk (standard deviation) of selected managers against the performance and risk of a market index for a specific period of time. The graph is broken down into 4 quadrants: Less Risk-Less Return, Less Risk-More Return, More Risk-More Return, and More Risk-Less Return. The risk index determines the intersection of the quadrants. In addition to the rate of return and standard deviation, the analysis also calculates optional risk statistics such as alpha, beta, and r-squared.

Julie Brown

Mrs. Brown is an Equity Investment Analyst at Tradition Investment Management with a unique blend of creative and financial experience. She works with the Portfolio Managers to analyze companies and prepare reports.

Before joining Tradition Investment Management, Julie ran a successful freelance business as a production artist. This experience in the creative world has given her a deep understanding of the internal operations of various industries and allows her to offer unique insights when it comes to investment opportunities. Julie holds an undergraduate degree in German Language with a specialization in International Finance from Florida State University, which has equipped her with a comprehensive understanding of global financial markets. During her time at university, Julie volunteered at the Center for New Liberalism, an offshoot of the Progressive Policy Institute (PPI). This experience further honed her analytical skills and reinforced her commitment to responsible, impactful investment strategies.

CHIEF OPERATING AND COMPLIANCE OFFICER

Hunter Halliburton, mba

(423) 782-6183

[email protected]

Mr. Halliburton is the Chief Operating Officer and Chief Compliance Officer at Tradition. Prior to Tradition, he worked during the last 16 years as a registered representative helping individuals and families plan for their financial futures.

He initially started with PFS Investments in 2006 and in 2014 he went independent, offering investments through Quest Capital Strategies, and finally through SA Stone Wealth Management, Inc. Mr. Halliburton is registered as an Investment Advisor Representative (Series 65). He holds a Bachelor of Science degree from the United States Military Academy at West Point, graduating in 1993, and earned an MBA from the University of Tennessee in Knoxville in 1998. He retired from the United States Army Reserve, and has worked in both the petroleum and pharmaceutical industries. He is married to Amy Halliburton, and they have three children, Hannah, Ella, and Aaron.

managing Director

Head of Marketing and Investor Relations

Art Williams

(561) 406-6765

[email protected]

Mr. Williams is a Managing Director and Head of Marketing and Investor Relations at Tradition. He has 36 years of experience in financial services.

Before joining Tradition, he was a Lead Advisor at CIG Capital Advisors. Prior to CIG, he was Head of Business Development at Disciplined Alpha, a long short equity hedge fund, and had the same role at Doric Capital, a long short equity hedge fund based in Hong Kong. Previous positions include Chief Operating Officer of Federal Street Partners, a fund of hedge funds whose assets peaked at $3.5 billion, and Co-President of Pine Grove Associates, a fund of hedge funds whose assets peaked at $2.5 billion, which was sold to Man Group PLC. Mr. Williams also established and managed the international institutional equity sales businesses for Morgan Stanley and Merrill Lynch in the Midwest, Texas, and Canada. In addition he managed the Northern Trust International Select Equity Fund. He has won the national platform tennis championships in three age categories, been ranked number one in the country five times, and was the co-captain of the Lafayette College men’s tennis team. He has also won the Distinguished Service Award from the Slattery Detachment of the Marine Corps League twice. Mr. Williams attended Vanderbilt University and holds an A.B. in American Studies from Lafayette College.

Mr. Williams holds the Series 7, 63 and 65 licenses from FINRA.

FOUNDER

Chief Investment Officer


Benjamin C. Halliburton, CFA

(673) 699-3890

[email protected]

Mr. Halliburton is the Founder and Chief Investment Officer at Tradition. He has been named PSN Manager of the Decade for two separate decades. He has over 35 years of professional investing experience.

Mr. Halliburton was the founder of Tradition and its predecessor companies. Prior to the predecessor companies, he was a partner, portfolio manager, research director, and investment policy committee member at Brundage, Story and Rose, which Bessemer Trust acquired, where he was responsible for the firm’s equity selection process and designed, developed, and managed the firm’s Disciplined Growth Strategy. Mr. Halliburton holds the Chartered Financial Analyst designation and earned an MBA from Duke’s Fuqua School of Business in 1990, where he was distinguished as a Fuqua Scholar. He earned a Bachelor of Science from Vanderbilt University, graduating Magna Cum Laude in 1985.