Disclosure

Plexus Financial Services, LLC (“PFS”) does not provide specific investment, tax, and/or legal advice and the information referenced/provided is not specific to any company’s or individual’s circumstances. These materials are general in nature and provided for educational purposes based upon publicly available information from sources believed to be reputable and reliable; we cannot assure the accuracy or completeness of these materials and as a result, personal diligence should be completed before relying or acting upon the information presented. Any general information referenced/provided is not be construed as personalized investment, tax, and/or legal advice. Always consult an advisor, attorney and/or tax professional regarding your specific situation.

This communication is strictly intended for individuals residing in the states where PFS is registered and does not provide any information regarding any offers or services directly provided by PFS. The information referenced/provided is not to be considered an offer to buy or sell, or a solicitation of any offer.

You may request receipt of PFS’s Form ADV, Privacy Policy Statement, Code of Ethical Behavior, and/or Conflict of interest Policy at any time by written request to communications@plexusfs.com. For additional details or questions regarding this or any information provided by or related to PFS please visit our website at www.plexusfs.com. PFS is located at 21805 W. Field Parkway, Suite 300, Deer Park, Illinois 60010. To contact us by phone please call (847) 307-6222.

PFS is a wholly owned subsidiary of The Plexus Groupe LLC. Advisory services are offered through Plexus Financial Services LLC, a registered investment advisor with the SEC which transacts business in states where it is properly registered, or is excluded or exempted from registration requirements, member FINRA www.finra.org, and the SIPC www.sipc.org. SEC registration does not constitute an endorsement of the firm by the Commission nor does it indicate that the adviser has attained a particular level of skill or ability.

Plexus Financial Services, LLC (“Plexus”) is a wholly owned subsidiary of The Plexus Groupe, LLC, which is a full-service retail insurance agency. Advisory services are offered through Plexus Financial Services LLC, a registered investment advisor with the SEC which transacts business in states where it is properly registered or is excluded or exempted from registration requirements. Plexus has adopted this privacy policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information.

Plexus provides investment services by means of its own internal operation and unaffiliated third-party service and product providers (for example, your account custodian or a money manager) at your election. The account custodian processes the investment transactions for your account. This firm and the product and service providers receive and maintain information about you that is related to your account.

Where Do We Obtain Your Information? The information that we have comes directly from you. This includes such information as your name, address, and Social Security number that you provided on applications, agreements or other forms. The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. In addition, we do not maintain at our office records of each of your transactions and holdings but do have access to those records via the Plan providers’ websites.

To Whom Do We Disclose the Information? We provide information about current or former Clients from the sources described above to parties outside of our firm only as described below:

To other companies as necessary to process your business. For example, we process your investment instructions through product and service providers with whom we have business agreements. The information that we obtained from you is given to the product and service providers for purposes of effecting transactions in your account and preparing your account statements. These parties must limit their use of the information to the purpose for which it was provided. Plexus may share nonpublic personal information without an Investor’s consent with unaffiliated third parties in the following situations, among others:

To comply with federal, state or local laws, rules and other applicable legal requirements;
To comply with a properly authorized civil, criminal or regulatory investigation, or subpoena or summons by federal, state or local authorities;
To protect or defend against fraud, unauthorized transactions (such as money laundering), lawsuits, claims or other liabilities;
To service providers of Plexus in connection with the administration and operations of the Fund and other Plexus affiliated products and services, which may include brokers, attorneys, accountants, auditors, administrators or other professionals; and
You may direct us, for example, to send account statements or other account information to a third party.

Confidentiality and Security: We restrict access to information about you to those employees and authorized agents who need to know that information in order to provide products or services to you. We maintain physical, electronic, and procedural safeguards as outlined in the attached policy statement to maintain the confidentiality of your information.

Changes to Our Privacy Policy: In the event there were to be a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you.

Questions: If you have questions about this privacy notice or about the privacy of your customer information, please call 847-307-6222.

CONFLICT OF INTEREST POLICY

At PFS, we fully recognize that conflicts of interest adversely affect the integrity of the private retirement system. At the least, the appearance of impropriety calls into question fiduciaries’ loyalty to participants. At worst, a conflict of interest can have a direct adverse impact on the Plan and its participants. For instance, a conflict of interest, gone unchecked, can result in the Plan paying more than reasonable compensation to service providers or result in fiduciaries offering mediocre and overly expensive investment options when superior products are available at equal or less expense costs. Conflicts of interest, therefore, can adversely affect the benefits available to participants at retirement; the exclusive purpose for which retirement Plans exist. PFS does not involve itself in self-dealing transactions and has policies and procedures to address self-dealing transactions by co-fiduciaries. We subscribe to and abide by the fundamental duty within the fiduciary standard of care, which is to manage delegated investment decisions for the exclusive benefit of the retirement Plan participant and their beneficiaries. We recognize that we have a responsibility to employ an objective, independent due diligence process at all times.

Within the Monitoring phase of our service delivery model, we continuously seek to (1) identify conflicts (or potential conflicts) that may impact the management of the Plan; (2) evaluate those conflicts and the impact they may have on the Plan and its participants; (3) determine whether the conflicts will adversely impact the Plan; (4) consider protections that would protect the Plan and participants from any potential adverse effect of the conflict (for instance, appointing an independent fiduciary to evaluate the investment or proposed service provider) and: (5) if the conflict adversely impacts the Plan and its participants, change service providers, investments or other circumstances related to the conflict.

PFS recognizes that although a conflict of interest may exist in connection with a proposed transaction, entering into the transaction may or may not be a breach of fiduciary duty — the determining factors are whether all fiduciaries prudently evaluated the conflict, and acted solely in the best interests of the participants and for the exclusive purpose of providing benefits. If a material adverse impact on the participants cannot be avoided or properly mitigated, entering into the transaction would not be prudent and would trigger a fiduciary breach.

Furthermore, if a conflict of interest is precluded under ERISA’s prohibited transaction rules, we will not, as a matter of law, allow the Plan to become a party to the transaction; even if the action were otherwise reasonable or profitable to the Plan. Absent an exemption, we recognize all fiduciaries are absolutely precluded from entering into a contemplated transaction if it meets the criteria of the prohibited transaction provisions of ERISA; even if doing so could otherwise be considered "prudent" and therefore satisfy ERISA.

Form ADV

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Plexus Financial Services

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