DISCLOSURE REGARDING TRADING AT FRONTIER

In an effort to better inform you about how we trade client accounts and to try to avoid any misunderstandings, we have outlined this detailed disclosure statement regarding trading at Frontier.

Frontier executes all trades on a “best efforts” basis.
This means that we do our best to execute all trades in a timely and accurate manner. We do not guarantee that trades will be initiated or settled within a particular time period, or at a particular price. Many things may delay trading. We will use reasonable efforts to accommodate requests but cannot ensure a particular outcome. It can take days or sometimes even weeks to fully invest an account, make trades in an account or liquidate all or part of an account, and procedures such as tax loss harvesting may be conducted over extended time periods.

Frontier is focused on long-term investing.
We make no effort to time the market or guess the direction of the market in the short-term. Sometimes there are delays in trading accounts. In volatile markets, share prices can swing dramatically, even in one day. This can result in a “missed opportunity” for the client. At other times the client may benefit. We expect these situations to even out over time and hope the value we add long-term through our investment process more than makes up for any missed opportunities

Frontier does not operate a “trading desk.”
Our trading operation bears little resemblance to the typical broker-dealer trading operation. At Frontier, no traders are anxiously monitoring price movements on the computer screen while working trades on the floor of the exchange. Our specialty is trading mutual funds at the custodial firms where our clients maintain their accounts. We do our best trading other types of securities, but we have no special expertise in those areas.

When given outside trading instructions, we merely act as “order takers.”
Most of the trades we execute are initiated internally, as part of our portfolio management responsibilities. We know what we are trying to accomplish and are responsible for getting those trades right. When advisors call us with specific trading instructions relating to an account, we will take the order and use reasonable efforts to execute it as directed. We are not responsible, however, if the instructions are unclear, based on misinformation or derived from faulty assumptions. Of course, if an instruction seems unclear, we will try to get clarification. Ultimately, the responsibility for overseeing the trade rests with the person issuing the instructions.

Frontier assumes no responsibility for losses, expenses, damages or lost opportunities in connection with any trade (including trades resulting from model changes), or for any delays in, or failures to initiate or complete a trade within a particular time period, unless such failure or delay was due to Frontier’s gross negligence or intentional or willful misconduct. Frontier assumes no responsibility for, and accepts no liability in connection with, instructions regarding the opening, closing, trading or management of an account, which are inaccurate, unclear, ambiguous, incomplete or which are based on incorrect assumptions or incomplete information. Frontier does not accept oral or telephonic instructions regarding the opening, closing, trading or management of an account and shall have no responsibility for any losses, expenses, damages or lost opportunities based on its failure to comply with oral or telephonic instructions in the event that they are given.