Ethics & Disclosure

Brokerage Recommendations

As Treece Investment Advisory Corp. does not have the discretionary authority to determine the broker dealer to be used or the commission rates to be paid, clients must direct Treece Investment Advisory Corp. as to the broker dealer to be used. In directing the use of a particular broker or dealer, it should be understood that Treece Investment Advisory Corp. will not have authority to negotiate commissions among various brokers or obtain volume discounts, and best execution may not be achieved. In addition, a disparity in commission charges may exist between the commissions charged to other clients.

For clients in need of brokerage or custodial services, Treece Investment Advisory Corp. will recommend the use of TFSC, an associated broker dealer with which it is affiliated by common control and ownership and where personnel of Treece Investment Advisory Corp. are licensed as sales representatives, to a client in need of assistance.  However, a client is not under any obligation to affect trades through any recommended broker. All clients are free to select any broker dealer of his or her choice.

Participation or Interest in Client Transactions 

Treece Investment Advisory Corp. has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. Treece Investment Advisory Corp.'s Code of Ethics describes the firm's fiduciary duties and responsibilities to clients, and sets forth Treece Investment Advisory Corp.'s practice of supervising the personal securities transactions of supervised persons with access to client information. Individuals associated with Treece Investment Advisory Corp. may buy or sell securities for their personal accounts identical to or different than those recommended to clients. It is the expressed policy of Treece Investment Advisory Corp. that no person employed by Treece Investment Advisory Corp. shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients.

To supervise compliance with its Code of Ethics, Treece Investment Advisory Corp. requires that anyone associated with this advisory practice with access to advisory recommendations provide annual securities holdings reports and quarterly transaction reports to the firm's Chief Compliance Officer. Treece Investment Advisory Corp. requires such access persons to also receive approval from the Chief Compliance Officer prior to investing in any IPOs or private placements (limited offerings).

Treece Investment Advisory Corp. requires that all individuals must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Treece Investment Advisory Corp.'s Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to discipline.

Treece Investment Advisory Corp. will provide a complete copy of its Code of Ethics to any client upon request to the Chief Compliance Officer at Treece Investment Advisory Corp.’s principal address.

Treece Investment Advisory Corp. may aggregate trades for itself or for its associated person with client trades, providing that the following conditions are met:

1. Treece Investment Advisory Corp.'s policies for the aggregation of transactions are fully disclosed in this Form ADV and separately to Treece Investment Advisory Corp.'s existing clients and the broker-dealer(s) (if any) through which such transactions will be placed;
2. Treece Investment Advisory Corp. will not aggregate transactions unless it believes that aggregation is consistent with its duty to seek best execution (which includes the duty to seek best price) for its clients and is consistent with the terms of Treece Investment Advisory Corp. 's investment advisory agreement with each client for which trades are being aggregated; and
3. No advisory client will be favored over any other client; each client that participates in an aggregated order will participate at the average share price for all Treece Investment Advisory Corp.'s transactions in a given security on a given business day, with transaction costs shared pro-rata based on each client's participation in the transaction.
4. Treece Investment Advisory Corp. will prepare, before entering an aggregated order, a written statement ('Allocation Statement') specifying the participating client accounts and how it intends to allocate the order among those clients;
5. If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the Allocation Statement; if the order is partially filled, it will be allocated pro-rata based on the Allocation Statement.
6. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the Allocation Statement if all client accounts receive fair and equitable treatment and the reason for different allocation is explained in writing and is approved by Treece Investment Advisory Corp.’s compliance officer no later than one hour after the opening of the markets on the trading day following the day the order was executed;
7. Treece Investment Advisory Corp.'s books and records will separately reflect, for each client account, the orders of which are aggregated, the securities held by, and bought and sold for that account;
8. Funds and securities of clients whose orders are aggregated will be deposited with one or more banks or broker-dealers, and neither the clients' cash nor their securities will be held collectively any longer than is necessary to settle the purchase or sale in question on a delivery versus payment basis; cash or securities held collectively for clients will be delivered out to the custodian bank or broker-dealer as soon as practicable following the settlement;
9. Treece Investment Advisory Corp. will receive no additional compensation or remuneration of any kind as a result of the proposed aggregation.

Privacy Disclosure Document

Treece Investment Advisory Corp’s primary client goal is to protect your privacy.  To conduct regular business, we may collect nonpublic personal information from sources such as:

• Information reported by you to us
• Information about your transactions with us, our affiliates, or others

As the Firm shares nonpublic information solely to service our client accounts, we do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law.

To provide the utmost in service, we may disclose the information below regarding customers and/or former customers, as necessary, to companies to perform certain services on our behalf, or as required by law.

• Information the firm receives from clients on applications (name, social security number, address, assets, etc.)
• Information about client transactions with our firm or others (account information, payment history, parties to transactions, etc.).
• At times, we may disclose nonpublic personal information to affiliated third parties, including Treece Financial Services Corp., a FINRA registered broker dealer under common ownership and control with Treece Investment Advisory Corp.  We may share any of the information that we collect as described above.

Information Safeguarding

Treece Investment Advisory Corp. will internally safeguard your nonpublic personal information by restricting access to only those employees who provide products or services to you or those who need access to your information to service your account. In addition, we will maintain physical, electronic and procedural safeguards that meet federal and/or state standards to guard your nonpublic personal information.

Portfolio Concentration

Treece Investment Advisory Corp. uses a management theory that strives to keep all of a client's funds invested in a mutual fund(s) that will appreciate from current economic conditions.  The result of this effort is that often a client's investments will be in one or two mutual funds.  Therefore, the account may experience volatility and concentration risk that would not be present in a more diversified portfolio.