Disclosure Statement

Fuller & Thaler claims compliance with the Global Investment Performance Standards (GIPS^®). Fuller & Thaler has been verified for the period from January 1, 1992 through September 30, 2009 by Beacon Verification Services. A copy of the verification report is available upon request.

Fuller & Thaler is an independent investment management firm registered with the U.S. Securities and Exchange Commission that manages primarily equity assets for primarily institutional investors. Fuller & Thaler seeks to identify mis-priced securities by exploiting insights from the field of behavioral finance.

Non-performance information is based on a representative account in the strategy. A composite contains all actual fee paying discretionary accounts in the strategy managed according to the composite criteria. Accounts no longer being managed by Fuller & Thaler remain in composite information to eliminate a survivorship bias. Net-of-Fees returns reflect deduction of transaction costs and actual estimated management and performance fees, as applicable. Net-of-Fees returns include the reinvestment of all dividend and interest income. Composite performance from January 1, 1992 to April 4, 1993 is based on the growth equity component of a fund ported to Fuller & Thaler. Cash returns on the carve-out were calculated based on an assumption of 3.5% cash with a 3-month T-bill return, contrary to the GIPS standards which require the allocation of actual cash returns.

Index includes the reinvestment of dividends (gross of tax withholding, unless otherwise noted above) but not interest or any other fees and expenses that would be involved in investing in the indices – the effect of such fees and expenses would be to lower the index returns by an undetermined amount. In comparing a strategy’s performance to any market index or to the U.S. T-bill, one should note the following differences: indices are generally more diversified and represent unmanaged results of long investments; a strategy is actively managed, may not be as diversified, may short, and may be more volatile. U.S. T-bills are fixed-income securities guaranteed by the U.S. government; an investment in a strategy is in equities and does not have such a guarantee by the government. The performance of an investment may vary depending on various factors, including the timing of cash flows. The U.S. Dollar is the currency used to express performance. Information is derived from sources believed to be accurate. The potential for profit is accompanied by the possibility of loss. Past performance is not indicative of future results.

The sub-advised mutual fund list includes mutual fund clients of Fuller & Thaler where Fuller & Thaler is the sole sub-adviser. Fuller & Thaler did not use performance based criteria to determine which clients to include on the list. It is not known whether the listed clients approve or disapprove of Fuller & Thaler or the advisory services provided.

A complete list and description of Fuller & Thaler’s composites is available upon request: contact us