The Allocation Portfolio program is an investment advisory program (“Program”) that allows Financial Advisors clients to invest in one of several predetermined discretionary model portfolios (“Model Portfolios”). The Program’s Model Portfolios are developed based upon the asset allocation guidelines provided by Douglas Bagwell Corporation Registered Investment Adviser ("Douglas Bagwell") and assets are allocated among various Portfolios of Exchange-Traded Funds (ETFs), Exchange-Traded Notes (ETNs), Closed-End Funds, Open-End Mutual Funds, Stocks, Bonds and other securities.

ETFs and ETNs are passively managed portfolios designed to track the performance of a basket of stocks or certain index. The ETFs, ETNs, Closed-End Funds, Open-End Mutual Funds and other securities within the Program are selected using a variety of criteria including, among others, their respective broad market or industry sector exposure. Douglas Bagwell monitors the ETFs, ETNs, Closed-End Funds, Open-End Mutual Funds and other securities allocated in the Model Portfolios and may replace an existing ETF, ETN, Closed-End Fund, Open-End Mutual Fund, or other security at any time.

The Program is designed for Financial Advisors seeking third-party investment management giving Douglas Bagwell full discretion over the accounts asset allocation-based investment strategies covering intermediate or long-term time horizon depending on the model selected. The program does not provide ongoing financial advice or services.

The Program Accounts are managed separately and are not pooled. Douglas Bagwell markets the Program through its Representatives and Solicitors. When opening a Program Account, and thereafter as is necessary, Douglas Bagwell obtains personal and financial information about the Financial Advisors client that may be used in determining the appropriateness of the investment approaches offered.