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Perspective

Q4 2023 Structured Credit Commentary

Market Review:

Both equity and fixed income investors enjoyed a nirvana like fourth quarter, as a goldilocks economy combined with a surprising easing pivot from the Fed drove investment returns to historical heights. The Fed could not have hoped for a better outcome for 2023, as most private-sector and Fed economists expected a recession in the second half of the year as a result of the cumulative impact of interest rate hikes would begin to take combined with the exhaustion of excess pandemic-related savings. Instead, the US economy is set to grow by 2.5% in Q4 after posting 4.9% growth in Q3. Annualized GDP growth is set to reach 2.6% in 2023, an improvement from 2.1% in 2022. The main surprising factor in 2023 was the indomitable consumer, as consumer spending increased by 3.1% year-over-year (YoY) despite a 5.25% increase in interest rates since Q1 2022. In addition to excess savings, US consumers benefited from the fixed coupon nature of their household debt. Moody’s Analytics estimates that 90% of household debt is fixed rate and US households greatly benefited from taking on or refinancing debt at low interest rates in 2020 and 2021. Despite the recent rise in consumer debt, the household debt servicing ratio remains under 10%, below the historical average of 11.1%. Additionally, the Fed achieved strong economic growth, and a close to all-time low unemployment rate of 3.7%, while making significant progress toward its aim of reducing inflation down to its 2% target rate. The Fed’s preferred inflation gauge, the PCE index, dropped to 2.6% YoY in November from a high of 7.1% in Q2 2022.  The broad inflation CPI index was down to 3.1% in November after reaching a high of 9.1% in Q2 2022. The significant progress on the disinflationary front prompted Fed chairman, Jerome Powell, to perform a dovish pivot at the December FOMC meeting, suggesting that the rate hiking cycle is likely done and that the Fed is shifting its attention to eventual rate cuts in 2024. The FOMC’s December Summary of Economic Projections (SEP) increased the number of rate cuts to 3 from 1 in the previous SEP.

Aided by lower inflationary numbers and the Fed’s dovish pivot, the market experienced a dramatic turnaround in Q4 as it began pricing in the first rate cut in March 2024 and pushing the number of rate cuts in 2024 to 6. The price action at the long end of the yield curve was equally dramatic. The yield on 10-year notes almost reached 5% in late October before the quarterly refunding announcement, which was heavily tilted toward short-term debt issuance, forced short covering from accounts that had shorted the long end of the curve which drove the 10-year yield back down to the same level where it started 2023, 3.88%. The yield curve managed 18bp of steepening between 2s and 10s in 2023. Despite the limited overall move in rates by year-end, 2023 experienced similar elevated rate volatility to 2022 levels, with the BofA MOVE index consistently above 100.

Despite QT starting in Q2 2022 and accounting for $1.3bn of the Fed’s balance sheet decline from Treasury and Agency MBS run-off, market liquidity was significantly boosted by the decline in the Fed’s RRP facility, which decreased from $2.5trn at the peak to $0.7trn by the end of 2023. This drop in the RRP facility helped fund the Treasury’s increased issuance without impacting bank reserve levels, allowing risk assets to move higher. The benchmark Bloomberg Aggregate index generated over 100% of its annual return in Q4, posting an impressive 6.79% to bring its total return to 5.53% for the year, despite being down almost 3.5% as of mid-October. For the year, the Bloomberg Aggregate outperformed equal duration Treasuries by 1.40%, as credit spreads tightened across all fixed income products.

IG Corporates partly erased their miserable performance in 2022 with an 8.52% return in 2023 and a 4.27% excess return relative to Treasuries. IG corporate spreads tightened by 31bp in 2023, finishing at 99bp option-adjusted spread (OAS), the tightest level since January 2022. High Yield corporates posted a total return of 13.44% for 2023, outperforming Treasuries by 8.86%. High Yield spreads tightened by 145bp in 2023 to 323bp OAS, the tightest level since April 2022. The High Yield sector has benefited from muted issuance volumes ($184bn in net issuance in 2023) and strong inflows into corporate credit ETFs. From the credit fundamentals side, according to Fitch, the HY TTM default rate increased to 3.1%, its highest level since April 2021. The leveraged loan default also climbed above 3% in November as elevated interest expense, and operational issues pushed six issuers to file for Chapter 11.

RMBS:

The Agency MBS index performed an amazing turnaround over the last two months of the year as it posted a 10% rally following a 5% decline through October. The current coupon 30-year nominal MBS spread tightened over 50bps from the October wides of 190bp to 140bp by year-end. The Bloomberg MBS index outperformed Treasuries by 1.33% in Q4 and by 0.68% over the entire 2023. The OAS declined from a peak of 82bp to 45bp. From an OAS perspective, the Agency MBS basis does not appear cheap relative to historical averages as interest rate volatility has been elevated from the start of the Fed’s hiking cycle. At the aggregate level, Ginnie 30yrs outperformed conventional 30yrs, while 30yrs outperformed 15yrs. At the coupon level, the belly coupons tended to perform the best, with UMBS 30yr 3.5s, UMBS 15yr 4s and Ginnie 30yr 3s being the best performers for their respective products. The net Agency MBS issuance for 2023 dropped significantly to $234bn from $431bn, as homes sales suffered a meaningful decline.

GSE CRT bonds were among the best performing structured credit and fixed income sectors in 2023. Limited issuance of just $9.4bn, well below $23.2bn in 2022, combined with high carry from the floating nature of their coupons and robust housing fundamentals, pushed spreads significantly tighter over the course of the year. On-the-Run (OTR) Single-A CRT spreads tightened from 225 to 130, BBB CRT spreads tightened from 325 to 210, BBs tightened from 525 to 290, and Bs tightened from 1150 to 575. Despite fears of a housing market slowdown, home prices increased on a national level by 4.8% YoY according to the S&P CoreLogic national index, as a limited supply of housing dominated high mortgage rates and low affordability.  Non-QM was the largest new issue sector in RMBS, with around 40% of the volume despite 2023 issuance being down $10bn. Just like other RMBS sectors, Non-QM had a very strong finish to the year, especially as interest rates rallied from 5% to 3.8%. OTR A1s (AAA) finished at 155bp over Treasuries, A2s (AA) at a spread of 195bp, A3s (A) at 225 and M1s (BBB) at 320bp. Over the course of the year, the credit curve flattened significantly with M1s tightening 265bp. In December, investors began to show a preference for 2020 and 2021 discount coupons backed by a low gross WAC collateral (3.5 to 5.0) that offer more price upside in a rate rally, with some subordinate tranches off seasoned discount collateral rallying by 7-10%.

RPL 2023 gross supply was $10.7bn, down from about $16.0bn in 2022.  Senior AAA spread levels tightened to 140bp, while AA and A subordinate tranches tightened to 175bp and 190bp over Treasuries. Issuance of Home Equity Lines of Credit (HELOCs) and Closed End Second mortgages (CESs) increased in 2023 to $4.5bn, up from $0.9bn in 2022, with a weighted average FICO of 740 and a combined LTV of 68%.  AAA HELOC tranches ended the year at 145bp while BBBs saw spreads tighten to 315bp. Legacy RMBS saw limited spread tightening in 2023 due to poor liquidity conditions, as the majority of RMBS accounts preferred to focus on more on-the-run sectors. Spreads tightened toward the end of the year with investment-grade subprime floater spreads trading through 200bp while non-IG subprime floaters cleared at spreads in the mid-to-high 200s.

CMBS:

Lower interest rates and greater prospects for a soft landing/no recession scenario catalyzed CMBS spreads to tighten in Q4, as better prospects for loan maturity resolutions encouraged cash-heavy investors to push up CMBS prices. The spread tightening was not uniform across CMBS subsectors. Most of the interest was directed towards new issue on-the-run conduit bonds with investors particularly drawn by stronger underwriting standards and the higher starting interest rates of 2023 vintage collateral. LCF (last-cashflow) AAA Conduit tranches tightened by 10bp in Q4 to finish the year at 134bp, while on-the-run BBB- spreads dropped inside 900bp to finish the year at 875bp, 75bp tighter for the quarter. However, unlike all other structured credit sectors, CMBS spreads were wider for the year as LCF AAAs widened by 5bp and BBB- tranches by 175bp.

Seasoned AS and investment grade mezzanine conduit bonds continued to widen in October as interest rates reached 5% and investors began to price in harsher maturity extension scenarios, but a rate rally in November/December triggered an improvement in pricing. Significant underperformance of CMBS relative to other fixed income sectors, along with a risk-on sentiment across the risk markets and favorable supply/demand technicals, should push spreads tighter for all CMBS subsectors in 2024. CMBS looks increasingly cheap relative to Corporates, with the spread difference between OTR Conduit BBB- CMBS and High Yield in the 99th percentile over the last 10 years. Furthermore, the paltry $46.5bn of gross supply in 2023, 54% below the already subdued 2022 issuance, against the backdrop of new money being raised to enter the distressed CRE space and the Fed hinting at an earlier than expected end to the QT program, creates compelling technical factors for CMBS going forward.

The SASB sector saw a 57% decline in issuance during 2023, and no office backed deals were issued for the year. Pricing varied across collateral and specific properties. In general, on-the run AAA SASB deals traded at 180bp for Industrial, 240bp for retail plazas and hospitality, and 290bp for regional mall backed deals. Several seasoned distressed deals still saw investment grade senior tranches clear at yields north of 10% to maturity and 8% to onerous extension scenarios.  The Small Balance Commercial sector saw just 1 deal priced in Q4 with spreads tighter by 25bp for AAAs at 250bp and by 55bp for BBBs at 470bp.

From a fundamental credit perspective, the Trepp 30+ delinquency rate increased to 4.51% in December, up from 3.04% 12 months ago and from 4.39% in Q3. The office sector continues to display the most problems with 30+ delinquencies accelerating from 1.68% in 2022 to 5.82% by the end of 2023. The Trepp special servicing rate increased by 1.67% in 2023 to finish the year at 6.78%. According to Trepp, the 12-month average loss severity on CMBS loans liquidated in 2023 was 56.4%, up by 3% from the end of 2022. Based on JPM Research estimates, about 73% of CMBS loans set to mature in 2023 were able to refinance on time. This percentage is likely to decline in 2024 amidst higher prevailing interest rates and worsening performance for office collateral.

ABS:

The ABS sector proved to be an exception among structured credit sectors with 2023 issuance exceeding 2022 by 5% ($256bn vs $243bn). Most of the issuance increase came from auto ABS and most of the increase was due to banks diversifying their Prime auto ABS funding through a securitization route as deposits became more expensive. Auto ABS accounted for $146bn of issuance with credit card and equipment, finishing a distant second and third, at $23bn and $22bn respectively. ABS sectors had the best performance in terms of excess returns versus Treasuries among broad securitized sectors in the Bloomberg Aggregate. The Bloomberg US ABS index outperformed Treasuries by 1.24% in 2023 with an absolute return of 5.54%. The ABS market benefits from high overall interest rates, and while ABS spreads are at the tightest levels in a year, they are still wider than they were before the pandemic.  Higher rated ABS tranches carry with them a “recession proof” label and should outperform other credit sectors due to their structural advantages and strong historical credit performance. One exception has been a couple of subprime Auto issuers that have declared bankruptcy, such as US Auto Sales and Automotive Credit Corporation. Across the subprime auto credit stack, spreads ended at the tightest levels for the year with AAAs trading at 100bp and BBBs at 250bp for on-the-run programmatic issuers. Based on JPM indices, Student Loan and Unsecured Consumer lending securities have been the best performing ABS collateral types with 6.63% and 6.37% return respectively.

From the credit side, ABS performance was a tale of three distinct time periods: pre-2021, 2021 and 2022, and 2023. Pre-2021 underwritten deals in subprime auto and unsecured lending benefited from the stimulus related to consumer de-levering, better credit underwriting, and an increase in vehicle prices. The 2021 and 2022 vintage deals had the most aggressive underwriting standards and credit performance has subsequently deteriorated. The 2023 vintage saw a tightening in the underwriting standards which has improved credit performance. Subprime Auto performance has deteriorated to the worst levels since 1994, with 60+ delinquencies reaching 6.5% in Q3.

CLO’s:

CLOs finished 2023 on a strong note with another positive quarter. Morningstar’s LSTA Leveraged loan index price almost reached $97 at the end of the year, up 4.5 points from the March lows. The current loan prices have now reached April 2022 levels. CLO new issuance totaled $113bn in 2023, down 12% from 2022 which was the second highest level in terms of issuance. The CLO credit curve continued to flatten in Q4. AAA tranches finished the year at 159bp DM, 30bp tighter relative to a year ago. BBBs were 82bp tighter and were trading at 438bp DM.BBs exhibited 103bp of tightening and managed to end the year at 875bp DM. The AAA CLO primary to secondary basis widened significantly in Q4 and was around 22bp at the end of the year.

Structured Notes:

Corporate structured notes finally managed positive performance as the impact of 12bp of curve steepening between 2s and 30s, along with a sudden yield plunge at the end of the year, prompted a rally in these bank-issued CMS spread floaters. The lower multiple CMS floaters rallied by 2 points into the mid-high 50s, while high multiple (8-20) floaters added a couple of points of price return reaching the  61/62 area. Given that these retail structured notes are trading at a 250-300bp discount to corporate bullets, we believe that there will be a strong investor interest in early 2024 with the gap between CMS floaters and bullets shrinking to 150-200bp spread discount, while prices will also benefit from curve steepening should it materialize.

Portfolio Attribution and Activity:

The Structured Credit Value composite returned 3.03% gross of fees (2.66% net of fees) for the quarter, underperforming the Bloomberg Aggregate Index which returned 6.82%. Both RMBS and CMBS posted strong performance given their lower duration.  The treasury position, being primarily 10-year maturity, contributed nicely.  The underperformance is primarily attributed to the lower duration of the portfolio relative to the Bloomberg Aggregate (2.4 yrs vs. 6.1 yrs), as interest rates rallied by 75bp.  Also, credit hedges deployed in the portfolio contributed a negative 55bp to the Q4 return.  In Q3 and Q4, we implemented a credit hedge using a credit default swap on the HY index (CDX HY), intended to hedge the riskiest portion of our CMBS allocation. While we are aware of the basis risk between CMBS and Corporate High Yield, we liked the CDX HY hedge relative to CMBS because of how wide the CMBS sector was trading relative to High Yield, with the spread differential between on-the-run BBB- conduit CMBS and Bloomberg HY OAS reaching the 99th percentile over the last 10 years during the quarter. While the return on Corporate Structured Notes was positive for the quarter, after combining it with the aforementioned CDX HY short, overall Corp return was negative.  Finally, our ABS allocation was a detractor to returns due to higher-than-expected losses on a subprime auto deal that followed the servicing transfer from a defunct servicer to Westlake.

Q4 2023 Portfolio Attribution and Net Return

SECTORALLOCATIONRETURNATTRIBUTION
RMBS40.03%4.43%1.74%
CMBS29.30%2.62%0.75%
ABS4.68%-1.24%-0.06%
CLO/CDO3.98%1.62%0.07%
CORP11.72%-1.69%-0.21%
GOVT3.65%8.18%0.37%
Cash6.64%0.05%0.00%
Total100%2.66%

Source: Ultimus Fund Solutions, Orange Investment Advisors

*Net performance shown is the Orange Investment Advisers (“the Firm”) Structured Credit composite in USD. Past performance is not indicative of future results.  Changes in exchange rates may have adverse effects. Net performance results reflect the application of the highest incremental rate of the standard investment advisory fee schedule to gross performance results. Actual fees may vary depending on, among other things, the applicable fee schedule and portfolio size. Investment management fees are available upon request. The Firm claims compliance with the GIPS® standards; this information is supplemental to the GIPS® report included in this material. Returns greater than one year are annualized.

Among contributors in Q4 were our overweight positions in RMBS and CMBS as spread tightening and carry (6.5% annualized realized carry in Q4) in both sectors had a positive impact on the performance. Despite spread tightening across many of our positions, the portfolio still had a 9.11% gross yield to maturity at the end of Q4.

We were fairly active during the quarter, trading over $30mm in net proceeds, excluding Treasuries and futures.  We turned over capital within the RMBS allocation by adding a seasoned Legacy RE-REMIC deal in the mid-60s while selling a few seasoned Prime 2.0 and Non-QM subordinate tranches that had reached their target prices. This trade replaced more liquid investment grade subordinate tranches at a 7% loss-adjusted yield with a less liquidity senior security at a 9% loss-adjusted yield. We are always monitoring structured credit sectors for these kinds of relative value opportunities, and this was an example of one. In CMBS, we particularly focused on adding longer duration AA/A subordinate tranches from the 2019-2021 vintages. Given the increase in rates since the start of Fed’s tightening cycle, these investment grade tranches have fallen into a price abyss due to lack of investor interest. However, given robust underwriting, these bonds are cheap relative to their credit fundamentals and can be acquired well below their intrinsic value.  With the Fed’s dovish pivot firmly entrenched in the market’s expectations, we think these longer duration, higher credit quality tranches will benefit from their high nominal yields, relative underperformance to other structured credit sectors, and significant money available on the sidelines for distressed credit opportunities.

Portfolio Outlook:

The portfolio currently outyields the Bloomberg Aggregate gross of fees by 4.6%, while exhibiting a dollar price 14 points lower.  Meanwhile, both Effective and Spread Duration are significantly lower than the Aggregate Index. We generally avoid interest rate risk in the portfolio, maintaining an effective duration around 2 years, but always between 1 and 3 years. We expect the Fed to initiate its rate cutting program by the end of Q2 and implement 4 rate cuts by the end of 2024, resulting in a Fed Fund’s rate in the 4.25-4.5 range and the 2-year potentially in the low 3s.  While it has been a fool’s errand to make any predictions regarding the direction of long-term Treasury rates given the number of factors that influence interest rate volatility, we believe that the 10-year will trade in the 3.25 – 4.25 range this year, resulting in a re-steepening of the yield curve. This, along with any spread tightening due to demand for steepeners, should be a positive for the Corporate Structured Note position.

We expect RMBS, which makes up 40% of the portfolio, to continue to perform well on a credit basis, providing solid carry and potential price return from additional spread tightening. CMBS valuations, for the most part, already reflect the worst-case scenarios for property values and borrowers’ inability or unwillingness to refinance loans at maturity.  We expect many problematic loans to be resolved via maturity extensions, forbearance plans, and other types of modifications rather than be liquidated at a fire sale level. We are assuming maturity extensions for many loan resolutions as a base case scenario when running cashflows to value bonds.

12/31/2023

SectorAllocationPriceYieldEff DurSprd Dur
RMBS40.03%$76.639.24%2.173.64
CMBS29.30%$77.4310.60%2.183.33
ABS4.68%$83.278.69%1.022.52
CLO/CDO3.98%$73.009.85%0.083.31
CORP11.72%$65.929.07%4.613.65
GOVT3.65%$99.093.66%7.08-
Cash6.64%$100.004.68%--
Total 100% $77.39 9.55% 2.363.11
Blbg Agg$91.704.50%6.26.2

Source: Ultimus Fund Solutions, Orange Investment Advisors

Sector information shown represents the quarterly average allocations and price, of the entire portfolio and should not be considered a recommendation to purchase or sell a particular security. All other information is as of 12/31/2023. There is no assurance that, as of the date of publication, the securities remain in the portfolio; such information is subject to change at any time and may differ, sometimes significantly, from individual client portfolios.

In addition, we expect the current CMBS conduit delinquency rate of 4.7% to rise to close to 10% over the next 12-24 months and are factoring that into cashflow projections as well.  In spite of these conservative assumptions, we still calculate yields between 8-12% for many of the investment-grade conduit tranches in the portfolio at current spreads. Also, given that the differential between new issue CMBS BBB- spreads and high yield corporates is currently in the 99.9 percentile over the last 10-years, we expect CMBS spreads to tighten over the course of 2024.

Overall, we expect Structured Credit to perform well in 2024, given our outlook for rates and our belief that some of the seemingly insatiable demand for fixed income credit, currently concentrated in Corporate sectors, will spill over to the smaller Structured Credit market due to compelling relative value.

GIPS® Report

Orange Investment Advisors Structured Credit Value Strategy Composite

Composite Inception Date: September 1, 2018
Composite Creation Date: July 2018

YearComposite PerformanceAnnualized 3-Year Standard DeviationTotal Assets
EndGrossActual NetModel NetBenchmarkCompositeBenchmarkInternal DispersionFirmCompositeNumber of Accounts
20237.48%5.91%6.79%5.53%2.73%7.24%N/A541.83316.241
2022-4.86%-6.27%-5.48%-13.01%5.88%5.85%N/A526.5327.791
20216.35%4.79%5.66%-1.54%5.37%3.40%N/A422.61294.191
202015.74%14.05%15.00%7.51%N/AN/AN/A274.65193.051
20198.92%7.31%8.21%8.72%N/AN/AN/A39.7439.741
20181.96%1.46%1.74%0.98%N/AN/AN/A35.7635.761

Firm Definition

Orange Investment Advisors is a Fixed income investment manager that invests primarily in U.S.-based Structured Credit securities. Orange Investment Advisors is defined as an independent investment management firm that is not affiliated with any parent organization. Policies for valuing investments, calculating performance, and preparing GIPS reports are available upon request.

Firm Verification Statement

Orange Investment Advisors claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. Orange Investment Advisors has been independently verified for the periods August 1, 2018 through December 31, 2021. The verification report is available upon request. 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 firmwide basis. Verification does not provide assurance on the accuracy of any specific performance report. This composite was created in July 2021, and the inception date is September 1, 2018. A list of composite descriptions and a list of limited distribution pooled funds are available upon request.

Composite Description

The Structured Credit Value Strategy Composite includes all fee paying SMAs and Funds that invest in Structured Credit based on Orange’s Active Value Security Selection approach which is a bottom-up, value-based investment strategy. The strategy seeks to provide a high level of income and total return with low sensitivity to interest rates and credit spreads by taking advantage of opportunities in the inefficient and non-indexed structured credit market. Derivatives, including options, futures, and swaps, and short positions may be used, primarily for hedging or managing certain risks, including interest or credit spread risk. The account minimum for the composite is $1 million.

Benchmark Description

The benchmark for the composite is the Barclays Bloomberg U.S. Aggregate Bond Total Return Index. Index returns reflect the reinvestment of income, but do not include any expenses, such as transaction costs and management fees.

Performance Calculation

Valuations are computed and performance is reported in U.S. dollars.

Returns include the reinvestment of income and are presented gross and net of fees. Gross returns are net of transaction costs. Actual net returns are net of actual transaction costs, management fees, as well as other fund operating fees and expenses. Model net returns are supplemental to actual net returns and are calculated by reducing the monthly composite gross return by a model fee of 0.05417%, which equates to an annual model fee of 0.65%, the highest fee charged to any SMA client. Actual fees may vary depending on, among other things, the applicable fee schedule and portfolio size. Past performance does not guarantee future results.

Investment Management Fee Schedule

The standard annual fee schedule is: 0.65% on the first $100 million, 0.55% on the next $150 million, and 0.45% on all assets above $250 million under management.

Composite Dispersion

Internal dispersion is calculated using the equal-weighted standard deviation of annual gross returns of those portfolios that were included in the composite for the entire year. It is not presented (“N/A”) when there are five or fewer portfolios in the composite for the entire year.

Standard Deviation

The three-year annualized standard deviation measures the variability of the composite gross returns and the benchmark returns over the preceding 36-month period.

Trademark

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.

Important Disclosures

© 2024. Easterly Asset Management. All rights reserved.

Easterly Asset Management’s advisory affiliates (collectively, “EAM” or “the Firm”), including Easterly Investment Partners LLC, Easterly Funds LLC, and Easterly EAB Risk Solutions LLC  (“Easterly EAB”) are registered with the SEC as investment advisers under the Investment Advisers Act of 1940, as amended. Registration does not imply a certain level of skill or training.  More information about the firm, including its investment strategies and objectives, can be found in each affiliate’s Form ADV Part 2 which is available on the www.sec.gov website. This  information has been prepared solely for the use of the intended recipients; it may not be reproduced or disseminated, in whole or in part, without the prior written consent of EAM.

No funds or investment services described herein are offered or will be sold in any jurisdiction in which such an offer or sale would be unlawful under the laws of such jurisdiction. No such fund or service is offered or will be sold in any jurisdiction in which registration, licensing, qualification, filing or notification would be required unless such registration, license, qualification, filing, or notification has been affected.

The material contains information regarding the investment approach described herein and is not a complete description of the investment objectives, risks, policies, guidelines or  portfolio management and research that supports this investment approach. Any decision to engage the Firm should be based upon a review of the terms of the prospectus, offering documents or investment management agreement, as applicable, and the specific investment objectives, policies and guidelines that apply under the terms of such agreement. There is no guarantee investment objectives will be met. The investment process may change over time. The characteristics set forth are intended as a general illustration of some of the criteria the strategy team considers in selecting securities for client portfolios. Client portfolios are managed according to mutually agreed upon investment guidelines. No investment  strategy or risk management techniques can guarantee returns or eliminate risk in any market environment. All information in this communication has been obtained from sources  believed to be reliable but cannot be guaranteed. Investment products are not FDIC insured and may lose value.

Investments are subject to market risk, including the loss of principal. Nothing in this material constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate. The information contained herein does not consider any investor’s investment objectives, particular needs, or financial situation and the investment strategies described may not be suitable for all investors. Individual investment decisions should be discussed with a personal financial advisor.

Any opinions, projections and estimates constitute the judgment of the portfolio managers as of the date of this material, may not align with the Firm’s opinion or trading strategies, and may differ from other research analysts’ opinions and investment outlook. The information herein is subject to change without notice and may be superseded by subsequent market  events or for other reasons. EAM assumes no obligation to update the information herein.

References to securities, transactions or holdings should not be considered a recommendation to purchase or sell a particular security and there is no assurance that, as of the date  of publication, the securities remain in the portfolio. Additionally, it is noted that the securities or transactions referenced do not represent all of the securities purchased, sold or recommended during the period referenced and there is no guarantee as to the future profitability of the securities identified and discussed herein. As a reminder, investment return and principal value will fluctuate.

The indices cited are, generally, widely accepted benchmarks for investment performance within their relevant regions, sectors or asset classes, and represent non managed investment portfolio. It is not possible to invest directly in an index.

This communication may contain forward-looking statements, which reflect the views of EAM and/or its affiliates. These forward-looking statements can be identified by reference to words such as “believe”, “expect”, “potential”, “continue”, “may”, “will”, “should”, “seek”, “approximately”, “predict”, “intend”, “plan”, “estimate”, “anticipate” or other comparable words. These forward-looking statements or other predications or assumptions are subject to various risks, uncertainties, and assumptions. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements. Should any assumptions underlying the forward-looking statements contained  herein prove to be incorrect, the actual outcome or results may differ materially from outcomes or results projected in these statements. EAM does not undertake any obligation to  update or review any forward-looking statement, whether as a result of new information, future developments or otherwise, except as required by applicable law or regulation.

Past performance is not indicative of future results.

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