IMPORTANT REGULATORY & ACQUISITION DISCLOSURES
Ownership and structure. INVST, LLC ("INVST") owns and controls McMillan Analysis Corporation, doing business as McMillan Asset Management ("McMillan"). McMillan is a subsidiary of INVST, and INVST is a control person of McMillan. INVST and McMillan remain separate legal entities that hold distinct regulatory registrations and maintain separate compliance programs; they are not a single advisory firm, and McMillan's advisory operations are not conducted under INVST's SEC registration.
Registrations. INVST is an SEC-registered investment adviser headquartered in Indianapolis, Indiana, offering wealth management and financial planning services. McMillan is a New Jersey-based investment adviser registered with the State of New Jersey and is registered with the Commodity Futures Trading Commission (CFTC) as a Commodity Trading Advisor (CTA) and Commodity Pool Operator (CPO), and is a member of the National Futures Association (NFA)]. McMillan is a related person of INVST as that term is used in Form ADV. Registration with the SEC, the CFTC, the NFA, or any state securities authority does not imply a certain level of skill or training, nor does it imply endorsement or approval by any regulator.
Scope of each firm's services. McMillan's operations — including its strategy newsletters, advisory services to pooled investment vehicles, and separately managed account (SMA) services provided to select clients and unaffiliated advisers — are conducted under McMillan's own registrations and independent compliance program, and are not supervised under INVST's SEC registration. INVST's wealth management and financial planning services are provided under INVST's SEC registration. Services available to a given client depend on which entity that client engages. INVST's SEC registration permits it to serve clients nationwide; McMillan's state registration and applicable exemptions govern the jurisdictions in which McMillan may provide advisory services.
Conflicts of interest. Because INVST controls McMillan, INVST has a financial incentive to recommend strategies or services associated with McMillan. This is a material conflict of interest. No INVST client is obligated to use any McMillan strategy, product, or service, and INVST clients may implement comparable strategies through unaffiliated providers. INVST's conflicts of interest, compensation arrangements, and affiliations are described in its Form ADV Part 2A brochure, which clients and prospective clients should read.
Availability and suitability. References to options, volatility, or risk-management strategies do not mean those strategies are available or appropriate for every client. Availability depends on individual suitability, investment objectives, risk tolerance, account type, custodial and options-approval requirements, and applicable eligibility standards, including client-qualification standards where performance-based compensation or private funds are involved. Not all clients will be eligible for or advised to use these strategies.
Purpose of this announcement. This announcement is for informational purposes only. It does not constitute personalized investment advice, nor is it an offer to sell, a solicitation of an offer to buy, or a recommendation of any security, private fund, newsletter subscription, or advisory service offered by INVST or McMillan. Any offer of interests in a private fund would be made only to eligible investors through that fund's offering documents. Statements regarding future integration, capabilities, or plans reflect current intentions only, are subject to change, and are not guarantees; no timeline for further integration has been established.
General risk disclosure. All investing involves risk, including the risk of loss of principal. Trading and investing, whether on margin or otherwise, carries a high level of risk and may not be suitable for all investors. No strategy, including a rules-based or risk-managed strategy, can eliminate risk, guarantee a profit, or protect against loss in a declining market. Past performance is not necessarily indicative of future results.
Options and derivatives risk disclosure. Options and other derivatives involve significant risk and are not suitable for all investors. An options purchaser may lose the entire premium paid. Certain strategies, including writing uncovered options and certain spread and futures positions, carry the risk of substantial or unlimited loss that may exceed the amount initially invested and may require additional margin on short notice. Transaction costs may be significant relative to the size of a position. Before trading options, investors should read Characteristics and Risks of Standardized Options, published by the Options Clearing Corporation, available at theocc.com or from your broker-dealer upon request. Trading in commodity interests, including futures and options on futures, involves substantial risk of loss and is not appropriate for all persons.
Additional information. Important disclosures regarding services, fees, conflicts of interest, and advisory personnel are available at INVST Disclosures (invst.com/firm-disclosure) and McMillan Disclosures (Disclosure — McMillan Asset Management).
