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State of California

Crane Asset Management, LLC is registered with the State of California. A copy of Crane's Form ADV filing (Parts 2A and 2B) can be accessed here. In addition, Crane's Form ADV (Part 1) can be downloaded from the SEC's website. Type in Crane's name in the field provided and follow the instructions on the site to download the information required.

Code of Ethics

Crane Asset Management, LLC has established a Code of Ethics, which applies to all officers, directors and employees (collectively, "Supervised Persons"). CAM will provide a copy of its Code of Ethics to all clients upon request. The general principles of the CAM Code of Ethics are as follows:

  1. All Supervised Persons at Crane Asset Management, LLC have a duty at all times to place the interests of clients first.

  2. All Supervised Persons at Crane Asset Management, LLC are required to comply with applicable securities laws.

  3. All Supervised Persons are required to conduct securities transactions in their personal accounts in such a manner as to be consistent with the principles outlined in the CAM Compliance Manual (and repeated in Part IV of the Code), and are required to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility.

  4. It is incumbent upon all Supervised Persons at Crane Asset Management, LLC that they be aware of the position of trust that they are in by virtue of their position at the Firm, and that they not take inappropriate advantage of their position.

  5. Information concerning the identity of security holdings and financial circumstances of clients is confidential. It is incumbent upon all Supervised Persons at Crane Asset Management, LLC that they observe their duty to maintain the privacy of client information at all times.

  6. Independence in the investment decision-making process is paramount.

  7. Failure to comply with the Firm's Code of Ethics may result in disciplinary action, including termination of employment.

 

 
John Frye is a member of the GuideVine Founder's Club