Pillar Pacific Mid Cap Growth Disclosures

Mid Cap Equity Composite – 07/01/1994 – 12/31/2020

Pillar Pacific Capital Management, LLC (“PPCM”) claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. PPCM has been independently verified for the periods September 1, 1993 through December 31, 2019.

A firm that claims compliance with the GIPS standards must establish policies and procedures for complying with all the applicable requirements of the GIPS standards. Verification provides assurance on whether the firm’s policies and procedures related to composite and pooled fund maintenance, as well as the calculation, presentation, and distribution of performance, have been designed in compliance with the GIPS standards and have been implemented on a firm-wide basis. The Mid Cap Growth Composite has had a performance examination for the periods July 1, 1994 through December 31, 2019. The verification and performance examination reports are available upon request.

GIPS® is a registered trademark of CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein.

1. Definition of Firm – Based on the way the firm holds itself out in the market place and in order to adhere to both the requirements and the spirit of the GIPS standards, we have adopted the broadest possible definition of the firm. For the purpose of complying with the GIPS standards, the firm is defined as Pillar Pacific Capital Management, LLC (“PPCM”), also known as Pillar Point Equity Management, an independent investment advisor registered under the Investment Advisers Act of 1940 (“Act”). The firm is defined to include assets managed across all offices, Pacifica and San Marino, California and include both the institutional and private client lines of business.

2. The performance results presented above reflect the Mid Cap Growth Composite (“Composite”) performance from its July 1, 1994 inception at Pillar Point Capital Management, Inc. (“Capital”) through May 31, 1999, and is then linked to the identical Composite from June 1, 1999 at PPCM. Capital began operating as an investment advisor on July 1, 1993, invested mainly in U.S.-based fixed income and equity securities, and formerly was an affiliate of PPCM. PPCM, whose name changed from Pillar Point Equity Management, LLC in October 2007, began operating as an investment adviser on June 1, 1999 and invests mainly in U.S.-based equity and fixed income securities. Prior to 2Q99, Firm Assets are those of Capital; from 2Q99 Firm Assets are those of PPCM. The Composite was previously named the Mid Cap Equity Composite. The Composite was created in December 1995.

3. PPCM implements an active, bottom-up investment process. Security analysis integrates a quantitative multi-factor valuation screening model and fundamental judgment. Portfolio construction applies an optimization process to build broadly diversified portfolios and provide benchmark-constrained risk management. The Composite includes all actual, fee-paying, discretionary accounts invested in diversified portfolios of medium capitalization equity issues, with few tax or other constraints that would otherwise impede the objective of maximizing total return. Medium capitalization equities are those with a market capitalization generally greater than $2 billion and less than $10 billion at the time of purchase.

4. The benchmark is the S&P Midcap 400® Index. The Russell Midcap® Growth Index is shown as additional information as the Composite has a growth orientation. The portfolios are actively managed and the structure of the actual portfolios and Composite may differ from the indices. Index returns reflect reinvestment of dividends but do not reflect fees, brokerage commissions, or other expenses of investing.

5. Returns are calculated in U. S. dollars and reflect the reinvestment of dividends. An annualized return is equivalent to that annual rate of return which, if earned in each year of the indicated multi-year period, would produce the actual cumulative rate of return (or inception to date or ITD return). Information regarding policies for valuing investments, calculating performance, and preparing GIPS Reports, and the list of composite descriptions are available upon request.

6. The three-year annualized ex-post standard deviation measures the variability of the monthly gross returns of the Composite and the benchmark(s) over the preceding 36 months. The internal dispersion of portfolio returns within the Composite is calculated on an asset-weighted gross-of-fee basis. The internal dispersion of portfolio returns within the Composite is not required when there are fewer than 6 portfolios included in the Composite for the entire annual period.

7. Performance results are presented net of trading expenses and are gross and net of investment management fees. The net of fee returns reflect actual fees paid, monthly or quarterly in arrears as per the investment advisory contract. Fees for certain accounts previously managed by Capital were set by Capital prior to the formation of PPCM, thus actual fees paid are different from the standard fee schedule. The current fee schedule is: 0.90% per annum on assets up to $15 million; 0.80% on the next $35 million and 0.65% on assets over $50 million; paid quarterly in arrears based on end-of-period assets.

8. Past performance is no guarantee of future results.