Cost of Trading Away in J.P. Morgan Securities LLC ("JPMS") Wrap Fee
Investment Advisory Programs
JPMS offers wrap-fee investment advisory services through several separate sales channels that provide discretionary portfolio
management of client assets by affiliated or unaffiliated Portfolio Managers (collectively referred to as “Wrap Fee Programs”).
This document provides information to clients who have, or may in the future have, a Wrap Fee Program account with a JPMS “Private
Client Advisor,” “Financial Advisor” or “Wealth Advisor,” about Portfolio Managers’ discretion to place client trade orders for
execution by broker-dealers other than JPMS. This practice is frequently referred to as “trading away.”
The information in this document is applicable to the following Wrap Fee Programs: Advisory Program, Chase Strategic Portfolio(“CSP”) Program, Customized Bond Portfolios (“CBP”) Program; Fixed Income Advisory Program, Investment Counseling Service(“ICS”) Program, J.P. Morgan Core Advisory Portfolio (“JPMCAP”) Program, J.P. Morgan Personal Advisors Program, Strategic
Investment Services (“STRATIS”) Program, and Unified Managed Account (“UMA”) Program.
The extent to which a Portfolio Manager chooses to trade away from JPMS can affect your total cost of investing in a Wrap Fee Program.
When a Portfolio Manager relies on JPMS as wrap fee program sponsor to execute its portfolio trades for client accounts in a Wrap
Fee Program, you are not charged commissions because trade execution by JPMS is covered by the wrap fee you pay to JPMS. The
wrap fee is an annualized asset-based fee that covers all advisory, administrative, custodial, and brokerage services provided by JPMS.
The wrap fee does not cover any (i) brokerage commissions or other charges resulting from transactions not effected through JPMS
or its affiliates; (ii) “mark-ups,” “markdowns,” and “dealer spreads” that we or other broker-dealers may receive when acting as
principal in certain transactions; (iii) certain costs or charges imposed by third parties, including odd-lot differentials, margininterest, transfer taxes, exchange fees, and other fees or taxes required by law; (iv) any account establishment, maintenance,
documentation and termination fees for Retirement Accounts; (v) the cost of investment manager fees and other expenses charged
by Funds; or (vi) any pass-through or other fees associated with investment in American Depositary Receipts.
When a Portfolio Manager chooses to trade away from JPMS with a broker-dealer other than JPMS, trade commissions are not coveredby the wrap fee you pay to JPMS and your account therefore may incur commissions, along with additional costs. Portfolio Managers
place orders in fixed income or debt securities with broker-dealers other than JPMS. For these fixed income trades, you will incur amark-up, mark-down or spread charged by the other broker-dealer that is not covered by the wrap fee. 1
0F

INVESTMENT AND INSURANCE PRODUCTS ARE:
● NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY ● NOT A DEPOSIT OR
OTHER OBLIGATION OF, OR GUARANTEED BY, JPMORGAN CHASE BANK, N.A. OR ANY OF ITS
AFFILIATES ● SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPALAMOUNT INVESTEDFixed income securities are primarily traded in dealer markets. These securities are directly purchased from or sold to a financial services firm
acting as a dealer (or principal). A dealer executing such trades may include a commission, a markup (on securities it sells), a markdown (onsecurities it buys) or a spread (the difference between the price it will buy, or “bid,” for the security and the price at which it will sell, or “ask,” forthe security) in the net price at which transactions are executed. The bid and ask are prices quoted by the dealer, so the client should understandthat a dealer’s bid price would be the price at which a client is selling their security, and the dealer’s ask price would be the price at which a clientis buying the security.

1Best Execution Obligations
Portfolio Managers have investment discretion over your account (or, in the case of the JPMCAP, CSP and UMA Programs, over those“sleeves” of the account consisting of separately managed account investment strategies). You direct Portfolio Managers in the Wrap
Fee Programs to place trade orders with JPMS for execution, which they do subject to their duty of “best execution.” Portfolio
Managers, as investment advisers, have an obligation to seek “best execution” of client trade orders. “Best execution” means that
Portfolio Managers have the responsibility to execute trades through those broker-dealers that they consider able to provide the best
qualitative execution under the circumstances. A Portfolio Manager may determine that JPMS or another broker-dealer’s execution
capabilities provide the most favorable option under the circumstances.
A Portfolio Manager commonly reviews several factors indicative of a broker-dealer’s trade execution quality in order to comply withits best execution obligation. A Portfolio Manager can examine the full range and quality of a broker-dealer’s services, including but
not limited to: the nature of the security, the size and type of transaction, the nature and character of relevant markets, the executing
broker’s execution, clearance and settlement capabilities and reputation, soft dollar arrangements, and the speed, knowledge,
efficiency, consistency and anonymity provided by the executing broker. Additional trading costs associated with trading away, as
described below in “Trading Away and Associated Costs,” may be one of several factors a Portfolio Manager evaluates when complying
with its best execution obligation. However, the best execution obligation does not require a Portfolio Manager to solicit competitive
bids for each transaction or to seek the lowest available cost of trade orders, as long as the manager reasonably believes that thebroker-dealer selected can be reasonably expected to provide clients with the best qualitative execution under thecircumstances. There is no single formula or process required for a Portfolio Manager to meet its best execution obligation; the factors
analyzed and the weight given to each factor can vary by Portfolio Manager.

Trade Aggregation and Trade Rotation Practices
Portfolio Managers may manage assets in other wrap fee programs besides those offered by JPMS, and may also manage institutionalor other accounts that are not part of any wrap fee program. In order to avoid buying or selling the same security for all client accounts
through multiple broker-dealers, a Portfolio Manager may decide to aggregate all such client transactions into a block trade that is
executed through one broker-dealer. This practice, known as “trade aggregation,” may allow a Portfolio Manager to obtain morefavorable execution, including more favorable pricing, than would otherwise be available if orders were not aggregated. Tradeaggregation may also aid a Portfolio Manager in avoiding an adverse effect on the price of a security that could result fromsimultaneously placing a number of separate successive or competing client orders. Trade aggregation by a Portfolio Manager
generally results in trading away from JPMS.
Alternatively, a Portfolio Manager may employ a trade rotation process where one group of clients has a transaction effected before
or after another group of a Portfolio Manager’s clients. A trade rotation process minimizes the impact of a Portfolio Manager’s tradingon the securities or markets in which a Portfolio Manager trades. As a client, you should be aware that a Portfolio Manager’s traderotation practices may at times result in a transaction being effected for your account near or at the end of the manager’s rotation.
In this event, your trade orders will bear the market price impact, if any, of those trades executed earlier in the manager’s rotation,
and, as a result, you may receive a less favorable net price for the trade. However, Portfolio Managers’ trade rotation procedures aredesigned to treat clients equitably and fairly over time.

Trading Away and Associated Costs
Because you will not pay additional commission costs when JPMS is the broker-dealer that executes trade orders in your Wrap Fee
Program account, Portfolio Managers may determine that JPMS’s execution capabilities as broker-dealer provide the most favorable
option for placing trade orders in your account. However, as noted above, a Portfolio Manager may choose to trade away if such
Portfolio Manager reasonably believes that another broker-dealer will provide a more favorable execution under the circumstances,notwithstanding any additional costs that you may incur.
When a Portfolio Manager trades away, the trades are executed with those broker-dealers that Portfolio Manager has determined will
provide best execution and are cleared and settled at JPMS. If a Portfolio Manager executes trade orders away from JPMS, you may
incur trading costs in addition to the fees charged by JPMS for your participation in the Wrap Fee Programs. The broker-dealer
executing the trade-away transaction may charge fees that may include commissions, as well as markups, markdowns or “spreads”
paid to market makers, which will be borne by you. Additionally, if a foreign currency transaction is required, a foreign broker-dealer
may receive compensation in the form of a dealer spread, markup or markdown. There may be other exchange or similar fees charged
by third parties, including but not limited to those relating to foreign currency conversion, creation of American Depositary Receipts(“ADRs”), and foreign tax charges. You will be able to tell by looking at your trade confirmation or account statement whether a tradewas placed away. For equity trades away, the commission will be provided on the account statement showing the additional cost
incurred for the trade away by a Portfolio Manager. Fixed income trades will indicate “traded away” and will not show the additional
cost incurred because trading costs are not identified separately for fixed income because they are incorporated into the net price ofthe trade.
Depending on the types of securities traded in a portfolio in the Wrap Fee Programs, certain Portfolio Managers may place all or
substantially all of certain types of trades with another broker-dealer for execution. For example, Portfolio Managers primarily tradeaway fixed income, and often trade away foreign security and small-cap equity strategies. In the Wrap Fee Programs, therefore, suchtypes of securities could be more costly to you than other types of strategies in which Portfolio Managers may more commonly place
trades with JPMS, the sponsoring broker-dealer for execution.
You should note in particular that JPMS, as Wrap Fee Program sponsor, does not accept fixed income trades for execution in the Wrap
Fee Programs. Because of this, when a Portfolio Manager that participates in a Wrap Fee Program wants to place a trade in a fixedincome security, like a bond, note, or debenture, we will require that such Portfolio Manager trade away. Accordingly, you should
expect that all fixed income trades in your account(s) in the Wrap Fee Programs will incur transactional costs in connection with thetrades not covered by the wrap fee you pay to JPMS.
You should review a Portfolio Manager’s Form ADV Part 2A Brochure, ask about a Portfolio Manager’s trading practices, and consider
that information carefully before selecting a Portfolio Manager and its investment strategy. In particular, you should carefully consider
any additional trading costs associated with a particular Portfolio Manager and investment strategy before selecting them for your
Wrap Fee Program account.

JPMS Wrap Fee Program Trading Away Information
The following chart contains trading away information provided by Portfolio Managers for the year ending December 31, 2023, unlessotherwise indicated. JPMS does not guarantee its accuracy. Portfolio Managers and Investment strategies are not listed if the Portfolio
Manager did not trade away. If a Portfolio Manager did not provide information for the 2023 calendar year, data reflects information
provided by the Portfolio Manager for 2021 calendar year.
All fixed income strategies are listed as they are expected to be traded away. Although Portfolio Managers are expected to trade away
fixed income strategies resulting in additional costs, the percentage of traded away and aggregate additional cost columns may reflectzeros because markups/markdowns or spreads are included in the net price and Portfolio Managers are therefore unable to provide
this information.
Information for investment strategies added to Wrap Fee Programs after December 31, 2023 is not available. Trading away information
for those strategies will be added in 2024 for the year ending December 31, 2024.
You should consult each Portfolio Manager’s Form ADV Part 2A brochure (“ADV”) and/or contact your JPMS Advisor to obtain
additional information about a Portfolio Manager’s trading away practices.
Past trading away practice in an investment strategy by a Portfolio Manager is not a guarantee that the Portfolio Manager will continue
the same practice in the future.
Investment Strategies that invest in foreign securities may incur additional costs assessed by the exchange(s) on which trades were
executed, such as exchange fees and taxes, and may also incur costs such as ADR conversion fees and currency conversion costs which
may be reflected in the aggregate additional costs figures below. For example, a Portfolio Manager may purchase a security via“ordinary shares” on a foreign exchange (which may charge a fee or tax on that trad0e), and then the bank may charge a fee to convert
the ordinary shares into American Depository Receipts (“ADR(s)”), and there may be currency conversion costs associated with thisordinary-to-ADR conversion.
As a result, the aggregate additional cost figures below are generally higher for Investment Strategies that invest in foreign securities
than for Investment Strategies that trade primarily in ADR securities (without first purchasing and subsequently converting ordinary
foreign shares) on U.S. exchanges or OTC markets. The below aggregate additional cost figures include disclosure to reflect if
additional ADR conversion and/or currency conversion costs were incurred and included.

Trading Away: Advisory Program

January – December 2023

Firm

Strategy

Dollar-weighted% of client
trades “tradedaway”

Appleton Partners, Inc.

Intermediate-Term Fixed Income

100.00%Aggregate additional cost
incurred by clients
participating in those
trades* (cps cents per
share) or (bps basis
points per share)$0.00

Appleton Partners, Inc.
Baird Investment
Management
Breckinridge Capital
Advisors, Inc.
Breckinridge Capital
Advisors, Inc.
Franklin Templeton
Investments
Franklin Templeton
Investments
GW&K Investment
Management
GW&K Investment
Management
GW&K Investment
Management
GW&K Investment
Management
Harding Loevner LP
Madison Investment
Advisors, LLC

Short Term Municipal

100.00%$0.00

Mid Cap Growth54.00%$0.00

Intermediate Tax-Efficient

100.00%$0.00

Limited Tax-Efficient

100.00%$0.00

Appreciation ESG

0.00%

$0.00

Dividend Strategy

0.00%

$0.00

Nuveen Asset Management

Pictet Asset Management
LimitedSage Advisory Services, Ltd.
Co
Schafer Cullen CapitalManagement, Inc.

GW&K Investment Management Total Return
Bond
GW&K Investment Management EnhancedCore Bond
GW&K Investment Management Short Term
Taxable Bond

100.00%100.00%100.00%

$0.00
$0.00
$0.00
$0.00

GW&K Municipal Bond Fund

100.00%Harding Loevner International Growth
Madison Investment Advisors Intermediate
Corporate Fund

30.60%

17.1 bps

100.00%$0.00

Nuveen Concentrated Preferred Securities

100.00%

There is no explicit trading
cost or commission
associated with step-out
trades for Nuveen
Concentrated Preferred
Securities strategy. Rather,
there may be an implicit
cost from the dealer’s bidask spread (difference
between the dealer’spurchase and sale price).

Pictet Clean Energy

35.50%$0.00

Sage Advisory Core Taxable

100.00%$0.00

Schafer Cullen International High Dividend

37.39%$0.00

Trading Away: CSP
Please note that J.P. Morgan Private Investments Inc. is the sub-advisor and Overlay Manager for all strategies in the Program andas such has investment discretion.

January – December 2023

Firm

Strategy

Dollar-weighted %of client trades“traded away”

J.P. Morgan Investment Management Inc

Intermediate Municipal Bond

100.00%Aggregate additional cost
incurred by clients
participating in those
trades* (cps cents per
share) or (bps basis points
per share)$0.0000

Trading Away: Customized Bond Portfolios

January – December 2023
Dollar-weighted %of client trades“traded away”

Aggregate additional cost
incurred by clients participatingin those trades* (cps cents per
share) or (bps basis points per
share)

100.00%0.00%

100.00%0.00%

100.00%0.00%

100.00%0.00%

100.00%0.00%

100.00%0.00%

100.00%0.00%

100.00%0.00%

100.00%0.00%

J.P. Morgan Preferreds

100.00%0.00%

JPM Yield Curve Enhanced CorpMA

100.00%

0.00%

Firm

Strategy

J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.
J.P. Morgan Investment
Management Inc.

J.P. Morgan 1-5 Year Municipal
Ladder
J.P. Morgan 1-10 Year Municipal
Ladder
J.P. Morgan 1-17 Year Municipal
Ladder
J.P. Morgan Long Municipal
Ladder
J.P. Morgan Ultra Short
Corporate Ladder
J.P. Morgan 1-5 Year Corporate
Ladder
J.P. Morgan 1-10 Year Corporate
Ladder
J.P. Morgan 1-5 Year Corporate
Cross-Over
J.P. Morgan 1-10 Year Corporate
Cross-Over

J.P. Morgan Investment
Management Inc.

Trading Away: ICS

January – December 2023

Firm

Appleton Partners, Inc.
Asset Preservation Advisors, Inc.
BlackRock Investment Management,
LLC
Credit Suisse Asset Management,
LLC
Credit Suisse Asset Management,
LLC
Dolan McEniry Capital Management,
LLC
Dolan McEniry Capital Management,
LLC
Eagle Asset Management, Inc.
J.P. Morgan Investment
Management Inc. (JPMIM)
Lazard Asset Management LLC
Lord, Abbett & Co. LLC
Madison Investment Advisors, LLC

Dollar-weighted% of client trades“traded away”

Aggregate additional cost
incurred by clients
participating in those trades*(cps cents per share) or (bpsbasis points per share)

100.00%$0.00

100.00%$0.00

100.00%$0.00

100.00%$0.00

100.00%$0.00

Dolan McEniry Core Plus

100.00%$0.00

Dolan McEniry Credit

100.00%$0.00

EGA Global Equity

0.00%

$0.00

JPM International ADR-MA

5.00%

$0.08

28.00%.01 CPS credit to .08 CPS Debit

100.00%$0.00

100.00%$0.00

StrategyAppleton High Grade Int
Gov/Credit
APA High-Quality Intermediate
Tax-Exempt
BlackRock Short-Term Taxable
FI SMACS Tax-Advantaged FI Limited
Duration
CS Tax-Advantaged FI 5yr
Target Duration

Lazard Asset Management
Equity Select ADR
Lord Abbett & Co. Long
Municipal MA
Madison Interm Corporate
Bond Wrap

1-10 bps *Additional cost is expressedin terms of an average of cents per
share or other unit.

Nuveen Asset Management

Nuveen Intermediate-Term
High Quality

100.00%

Where Nuveen Asset Management
trades away, clients generally incur
implicit transaction costs and fees in
addition to the wrap fee. These fees
are generally in the form of mark-ups
and mark-downs, or spreads, earned
by the relevant securities dealer (notNuveen Asset Management or a
Nuveen affiliate) in addition to thewrap fee payable to the wrap
program sponsor.
For secondary market trades, dealer
trading mark-ups typically range
from 1 to 10 basis points (a few cents
to several dollars) per bonddepending on several factors,
including position size, market
strength or weakness and holding
period among others. For primarymarket (new issue) trades, there areno additional trading costs.

Aggregate additional cost
incurred by clients participatingin those trades* (cps cents per
share) or (bps basis points per
share)

Firm

Strategy

Dollar-weighted% of client trades“traded away”

Parametric Portfolio Associates
LLC

Parametric TABS Muni. LadderLong Plus

0.00%

$0.00

Payden & Rygel

Payden & Rygel Core Bond

100.00%$0.00

Payden & Rygel

Payden & Rygel Low Duration

100.00%$0.00

100.00%$0.01

54.96%$0.00

100.00%$0.00

100.00%$0.00

Sagewood Asset Management LLC
Schafer Cullen CapitalManagement, Inc.
Shenkman Capital Management,Inc.
Shenkman Capital Management,
Inc.

Sagewood Volatility Yield
Strategy Comp
Schafer Cullen Emerging MktsHigh Div
Shenkman Capital Mgt
Convertible Comp
Shenkman High Yield SMA

Trading Away: STRATISJanuary – December 2023

Manager Name

Strategy Name

Dollar-Weighted
Percentage of Client
Trades Stepped Out

Additional Cost
Incurred by Clients
Participating in
those Trades*

100.00%$0.00

100.00%$0.00

39.00%$0.00

48.00%$0.00

Atlanta Capital Management

Appleton Partners Intermediate
Municipal
Appleton Partners Short Term
Municipal
Atlanta Capital High Quality
Small CapAtlanta Capital SMID-Cap

Baird Equity Asset Management

Baird Mid-Cap Growth Equity

58.00%$0.00

BlackRock Investment Management, LLC

BlackRock Intermediate Muni FI
Capital Group Global Equity
SMA
Capital Group International
Equity SMA

100.00%

$0.00

1.32%

$0.03

51.23%$0.05

29.00%

6bps for commission,
ADR conversion fee
ranged from (-0.05 to0.05), and local
market taxes vary bycountry

Appleton Partners, Inc.
Appleton Partners, Inc.
Atlanta Capital Management

Capital Group
Capital Group

Delaware Investments

Macquarie Intl. ADR Eq.
(Mondrian) (SMA)

0.00%

$0.00

Franklin Templeton Investments

Federated Strategic Value
Dividend MA
ClearBridge Appreciation

53.51%$0.64

Franklin Templeton Investments

ClearBridge Appreciation ESG

22.59%$0.69

Franklin Templeton Investments

ClearBridge Dividend Strategy
GW&K Total Return Bond
Strategy

52.21%$1.54

100.00%$0.00

Federated Investment Counseling

GW&K Investment Management

Manager Name

Strategy Name

Dollar-Weighted
Percentage of Client
Trades Stepped Out

GW&K Investment Management

GW&K Municipal Bond Strategy

100.00%Additional Cost
Incurred by Clients
Participating in
those Trades*$0.00

Harding Loevner LP

Harding Loevner Intl Eq ADR

37.12%

16.7 bps

Kayne Anderson Rudnick Investment
Management, LLC
Kayne Anderson Rudnick Investment
Management, LLC

Kayne Anderson Rd SC Quality
Value Wrap

18.89%$0.0120

Kayne Anderson Rud SMID Core

23.12%$0.0191

Lord, Abbett & Co. LLC

Lazard Asset Management (Asiaex Japan)
Lazard Emerging Markets Equity
Sel ADR
Lord Abbett Long Municipals

100.00%.01 CPS credit to .08
CPS Debit.01 CPS credit to .08
CPS Debit$0.00

Madison Investment Advisors, LLC

Madison Interm Govt/Corp Bond

100.00%$0.00

Madison Investment Advisors, LLC
Pacific Investment Management Co. /Allianz

Madison Interm Corp BondPIMCO Total Return Managed
Account

100.00%$0.00

100.00%$0.00

Pictet Asset Management Limited

Pictet Clean Energy SMA

35.50%$0.00

Sage Advisory Services, Ltd. Co

Sage Core Taxable Fixed Income

100.00%$0.00

Sage Advisory Services, Ltd. Co

Sage Intermediate Fixed Income

100.00%$0.00

Schafer Cullen Capital Management, Inc.

Schafer Cullen Intl Hi Div ADR
Schafer Cullen High Dividend
Value Eq
Schafer Cullen Enhanced Equity
Income31.84%

$0.00

0.35%

$0.00

0.00%

$0.00

Seix High Quality High Yield

0.00%

$0.00

Lazard Asset Management LLC
Lazard Asset Management LLC

Schafer Cullen Capital Management, Inc.
Schafer Cullen Capital Management, Inc.
Seix Investment Advisors LLC

0.00%
15.00%

Trading Away: UMA

January – December 2023
Please note that (a) Envestnet Asset Management (“Envestnet”) is the Overlay Manager for all strategies in the Program, (b) the 0%
shown for Envestnet applies to the equity strategies for which Envestnet alone has investment discretion, and (c) Envestnet and theother managers shown have joint investment discretion for the fixed income strategies.

Manager Name

Strategy Name

DollarWeighted
Percentage ofClient Trades
Stepped Out

Additional Cost
Incurred by
Clients
Participating in
those Trades*

100.00%$0.00

100.00%$0.00

Appleton Partners, Inc.

Appleton Partners Short Term Tax Exempt Fixed
IncomeAppleton Partners Tax Exempt Fixed Income

GW&K Investment Management

GW&K Tax-Exempt Fixed Income

100.00%$0.00

GW&K Investment Management

GW&K Total Return Bond Strategy

100.00%$0.00

Appleton Partners, Inc.

Additional Cost
Incurred by Clients
Participating in those
Trades*Manager Name

Strategy Name

Dollar-Weighted
Percentage of Client
Trades Stepped Out

Madison Investment
Advisors, LLC
Madison Investment
Advisors, LLC
Seix Investment Advisors
LLC

Madison Taxable Fixed Income (Corporate
Only)

100.00%$0.00

Madison Taxable Fixed Income

100.00%$0.00

Seix Investment High Yield Taxable Fixed
Income

0.00%

$0.00

Last Updated: July 25, 2024