Disclosure of Order Routing Practices – SEC Rule 606

McDonald Partners, LLC (“MDP”) clears all of its equity and options trades through RBC Correspondent Services, a division of RBC Capital Markets, LLC.

In accordance with SEC Rule 606 (Formerly Rule 11Ac1-6), MDP has adopted the Best Execution/Order Routing Report prepared by RBC Correspondent Services, a division of RBC Capital Markets, LLC.

You may access this report via this link.

Additionally, you may obtain a hardcopy of the Best Execution/Order Routing Report by contacting MDP’s Compliance Department at Compliance@mcdonald-partners.com or (866) 899-2997.

Additional Disclosures and Terms of Service

Legal Disclosures: McDonald Partners, LLC is a registered investment adviser with the United States Securities and Exchange Commission (“SEC”). Any reference to or use of the terms “registered investment adviser” or “registered,” does not imply that McDonald Partners or any person associated with McDonald Partners has achieved a certain level of skill or training. McDonald Partners may only transact business or render personalized investment advice in those states and international jurisdictions where we are registered, notice filed, or where we qualify for an exemption or exclusion from registration requirements. The purpose of this Website is to provide general information on our products and services only and should not be construed as a solicitation to effect, or attempt to effect, either transactions in securities or the rendering of personalized investment advice over the Internet. Any communications with prospective clients residing in states or international jurisdictions where McDonald Partners and its advisory affiliates are not registered or licensed shall be limited so as not to trigger registration or licensing requirements.

Terms of Service: PLEASE READ THE FOLLOWING TERMS AND CONDITIONS CAREFULLY. THEY GOVERN YOUR ACCESS AND USE OF THIS WEBSITE.

BY ACCESSING OR USING THIS WEBSITE, YOU AGREE TO BE BOUND BY THESE TERMS AND CONDITIONS AND ACCEPT THEM IN FULL, AS THEY MAY BE MODIFIED BY MCDONALD PARTNERS FROM TIME-TO-TIME AND POSTED ON THIS WEBSITE.

No Warranties: Although McDonald Partners attempts to provide accurate information, names, images, pictures, logos, icons, documents, and materials (collectively, the “Contents”) on the Website, it makes no representation, endorsement, or warranty that such Contents are accurate or suitable for any particular purpose. THE WEBSITE AND ITS CONTENTS ARE PROVIDED ON AN “AS IS” BASIS. USE OF THE WEBSITE AND ITS CONTENTS IS AT THE USER’S SOLE RISK. THE WEBSITE AND ITS CONTENTS ARE PROVIDED WITHOUT ANY REPRESENTATIONS, ENDORSEMENTS, OR WARRANTIES OF ANY KIND WHATSOEVER, EITHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, ANY WARRANTIES OF TITLE OR ACCURACY AND ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT, WITH THE SOLE EXCEPTION OF WARRANTIES (IF ANY) WHICH CANNOT BE EXPRESSLY EXCLUDED UNDER APPLICABLE LAW. AS NOTED BELOW.

Limitation of Liability: IN NO EVENT WILL MCDONALD PARTNERS OR ITS SUBSIDIARIES, AFFILIATES, CONTRACTORS, OR THEIR RESPECTIVE EMPLOYEES BE LIABLE FOR ANY DAMAGES, INCLUDING, WITHOUT LIMITATION, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, WHETHER UNDER A CONTRACT, TORT OR ANY OTHER THEORY OF LIABILITY, ARISING IN CONNECTION WITH ANY PARTY’S USE OF THE WEBSITE OR IN CONNECTION WITH ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, LINE SYSTEM FAILURE, LOSS OF DATA, OR LOSS OF USE RELATED TO THIS WEBSITE OR ANY WEBSITE OPERATED BY ANY THIRD PARTY OR ANY CONTENTS OF THIS WEBSITE OR ANY OTHER WEBSITE, EVEN IF MCDONALD PARTNERS IS AWARE OF THE POSSIBILITY OF SUCH DAMAGES.

Third Party Links, Products and Services Disclaimer: We provide links to the sites of affiliated companies and certain other businesses. We are not responsible for examining or evaluating, and we do not warrant the offerings of, any of these businesses or individuals or the content of their Websites. McDonald Partners does not assume any responsibility or liability for the actions, product, and content of all these and any other third parties. You should carefully review their privacy statements and other conditions of use. You will use these links at your own risk.

Copyrights and Trademarks: All content included on this Website, such as text, graphics, logos, button icons, images, photos, data compilations, and software, is the property of McDonald Partners or its content suppliers and is protected by United States and international copyright laws. The compilation of all content on this Website is the exclusive property of McDonald Partners and protected by U.S. and international copyright laws. You may not modify, publish, transmit, participate in the transfer or sale of, reproduce, create derivative works from, distribute, perform, display, incorporate into another website, or in any other way exploit any of the content, in whole or in part without the specific permission of McDonald Partners. All software used on this Website is the property of McDonald Partners or its software suppliers and is protected by United States and international copyright laws.

McDonald Partners’ graphics, logos, page headers, button icons, scripts, and service names are trademarks, registered trademarks or trade dress of McDonald Partners in the U.S. and/or other countries. McDonald Partners’, trademarks and trade dress may not be used in connection with any product or service that is not McDonald Partners in any manner that is likely to cause confusion among customers or in any manner that disparages or discredits McDonald Partners. All other trademarks not owned by McDonald Partners that appear on this Website are the property of their respective owners, who may or may not be affiliated with, connected to, or sponsored by McDonald Partners.

Transmissions to and from this Website: Except where expressly indicated otherwise, transmissions to and from this Website or directed to McDonald Partners including E-mails, are not sent in a secure form and can be intercepted by third parties and may not be immediately received by the appropriate business unit at McDonald Partners. Please do not use E-mail to send us communications which contain confidential information, which we require to be in writing, or which need our immediate attention. Please contact us at through the form on the Contact Us page of our Website. Any transmission to this Website, including E-mails shall be deemed and remain the property of McDonald Partners. McDonald Partners shall be free to use, for any purpose, any ideas, concepts, know-how, or techniques provided by a Website user to McDonald Partners through this Website.

License and Site Access: McDonald Partners grants you a limited license to access and make personal use of this Website and not to download or modify anything, or any portion of it, except with express written consent of McDonald Partners. This license does not include any resale or commercial use of this Website or its contents; any collection and use of any product listings, descriptions, or prices; any derivative use of this Website or its contents; any downloading or copying of account information for the benefit of another merchant; or any use of data mining, robots, or similar data gathering and extraction tools. This Website or any portion of this Website may not be reproduced, duplicated, copied, sold, resold, visited, or otherwise exploited for any commercial purpose without express written consent of McDonald Partners. You may not frame or utilize framing techniques to enclose any trademark, logo, or other proprietary information (including images, text, page layout, or form) of McDonald Partners without express written consent. You may not use any meta tags or any other “hidden text” utilizing McDonald Partners’ name or trademarks without the express written consent of McDonald Partners. Any unauthorized use terminates the permission or license granted by McDonald Partners. You are granted a limited, revocable, and nonexclusive right to create a hyperlink to the home page of McDonald Partners so long as the link does not portray McDonald Partners, or its products or services in a false, misleading, derogatory, or otherwise offensive matter. You may not use any McDonald Partners’ logo or other proprietary graphic or trademark as part of the link without express written permission.

Intended Audience: The information provided on this Website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject McDonald Partners or its affiliates to any registration requirement within such jurisdiction or country. McDonald Partners is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser pursuant to the Investment Advisors Act of 1940. McDonald Partners does not claim that the products or services in this Website are available in any particular jurisdiction or appropriate for any particular investor. If you choose to access this Website from a location other than the United States, you do so on your own initiative, and you are responsible for compliance with any applicable local laws.

No Offer or Advice: This Website does not constitute an offer to sell or a solicitation of an offer to buy any security that may be referenced on or through this Website. Nor does this Website constitute an offering or recommendation by McDonald Partners of any security, investment management service, or advisory service. McDonald Partners does not provide investment advice, tax advice, or legal advice through this Website, and you agree that this Website will not be used by you for such purposes. McDonald Partners does not represent that the securities, products, or services discussed on, or accessible through, this Website are suitable for any particular investor. You acknowledge that your requests for information are unsolicited, and the provision of any information through this Website shall not constitute or be considered investment advice, or an offer to sell, or a solicitation of an offer to buy any security.

Termination of Right to Use Website: McDonald Partners reserves the right to terminate your right to use this Website if you violate any of these Terms of Service. Upon termination of your right to use the Website, McDonald Partners will remove your account privileges. McDonald Partners will have no obligation to return to you your submitted data. The disclaimers and limitations of liabilities set forth in these Terms of Service shall survive any such termination. Your sole recourse and remedy if McDonald Partners terminates your right to use this Website, is to receive a refund for any products paid for but not processed or fulfilled by McDonald Partners if any.

Exclusions and Limitations: Some Jurisdictions do not allow the exclusion of certain warranties or the limitation of liability for incidental or consequential damages. Accordingly, some of the limitation may not apply to you.

Governing Law/Jurisdiction: These Terms of Service will be governed by and construed in accordance with the laws of the State of Ohio, without giving effect to any principles of conflicts of laws. Any action seeking legal or equitable relief arising out of or relating to this Website or Terms of Service, sole jurisdiction shall reside with the appropriate State or Federal Court located in Cleveland, Ohio. A printed version of these Terms of Service will be admissible in judicial and administrative proceedings based upon or relating to these Terms of Service to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

If any provision of the Terms of Service shall be unlawful, void or for any reason unenforceable, then that provision shall be deemed severable from the Terms of Service and shall not affect the validity and enforceability of any remaining provisions. McDonald Partners makes no representation that the Terms of Service comply with the laws of any other country. Visitors who use the Website and/or services and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. By virtue of your use of the Website, you agree not to transfer, by electronic transmission or otherwise, any materials derived from the Website and/or services in violation of any laws.

Waiver: No waiver by McDonald Partners of any right under or term or provision of these Terms and Conditions will be deemed a waiver of any other right, term, or provision of these Terms and Conditions at that time or a waiver of that or any other right, term, or provision of these Terms and Conditions at any other time.

Privacy: Please review our Privacy Notice, which also governs your visit to www.mcdonald-partners.com to understand our practices.

The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”).

The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP® certification in the United States.

To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:

• Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning;
  
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances;
  
• Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and
  
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP®professionals.

Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks:

• Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and
  
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients.

CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification.

CHARTERED FINANCIAL ANALYST (CFA®)
This designation is offered by the CFA® Institute (formerly the Association for Investment Management and Research [AIMR]). To obtain the CFA® charter, candidates must successfully complete three exams and gain at least three (3) years of qualifying work experience, among other requirements. In passing these exams, candidates demonstrate their competence, integrity and extensive knowledge in accounting, ethical and professional standards, economics, portfolio management and security analysis.

ACCREDITED INVESTMENT FIDUCIARY (AIF®)
The AIF® designation certifies that the recipient has specialized knowledge of fiduciary standards of care and their application to the investment management process. To receive the AIF® designation, individuals must complete a training program, successfully pass a comprehensive, closed-book final examination under the supervision of a proctor and agree to abide by the AIF® Code of Ethics. In order to maintain the AIF® designation, the individual must annually renew their affirmation of the AIF® Code of Ethics and complete six hours of continuing education credits. The certification is administered by the Center for Fiduciary Studies, LLC (a Fiduciary360 (fi360) company).

CHARTERED RETIREMENT PLANS SPECIALIST (CRPS®)
The CRPS® Program is specifically targeted at professionals who design, install, and maintain retirement plans for the business community. Continued use of the CRPS® designation is subject to ongoing renewal requirements. Every two years, individuals must renew their right to continue using the CRPS® designation by completing 16 hours of continuing education; reaffirming to abide by the Standards of Professional Conduct, Terms and Conditions; and self-disclose any criminal, civil, self-regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct.

CERTIFIED PRIVATE WEALTH ADVISOR (CPWA®)
The CPWA® certification is administered by Investment Management Consultants Association. The CPWA® designation signifies that an individual has met initial and on-going experience, ethical, education, and examination requirements for the professional designation, which is centered on private wealth management topics and strategies for high-net-worth clients. Prerequisites for the CPWA® designation are: a Bachelor’s degree from an accredited college or university or one of the following designations or licenses: CIMA®, CIMC®, CFA®, CFP®, ChFC® or CPA® license; acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory requirements; five years of professional client-centered experience in financial services or a related industry; and two letters of reference from an IMCA member, professional supervisor, or currently licensed professional in financial services or a related industry. CPWA® designees have completed a rigorous educational process that includes self-study requirements, an in-class education component, and successful completion of a comprehensive examination. CPWA® designees are required to adhere to IMCA’s Code of Professional Responsibility and Rules and Guidelines for Use of the Marks. CPWA® designees must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through Investment Management Consultants Association (IMCA).

FINANCIAL PARAPLANNER QUALIFIED PROFESSIONAL™ (FPQP®)
The Financial Paraplanner Qualified Professional™ designation is issued by The College for Financial Planning. Individuals who hold the FPQP® designation have completed a course of study encompassing the financial planning process, the five disciplines of financial planning and general financial planning concepts, terminology and product categories. Additionally, individuals must pass an end-of-course examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements.

CHARTERED RETIREMENT PLANNING COUNSELOR (CRPC®)
The Chartered Retirement Planning Counselor designation is issued by The College for Financial Planning. Individuals who hold the CRPC® designation have completed a course of study designed for advisors focused on retirement planning for individuals. There is a specific focus on clients’ pre and post retirement needs, as well as issues related to asset management and estate planning. Additionally, individuals must pass an end-of-course examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements.

CERTIFIED PLAN FIDUCIARY ADVISOR (CPFA®)
The Certified Plan Fiduciary Advisor® credential is issued by the National Association of Plan Advisors (NAPA). Individuals who hold the CPFA® designation have completed a course of study designed to demonstrate the expertise required to act as a plan fiduciary or help plan fiduciaries manage their roles and responsibilities. Individuals must pass an end-of-course examination that assesses a candidate’s knowledge of key retirement plan concepts commensurate with professional retirement plan advisor standards. Candidates must earn a passing score of 70% or greater on the NAPA CPFA® exam to qualify for NAPA CPFA® credentialed membership. All designees have agreed to abide by the ARA Code of Professional Conduct and are subject to a disciplinary process. NAPA CPFA® designation holders must complete 10 hours of Continuing Education (“CE”) each calendar year following the calendar year the NAPA CPFA® designation is earned. CE hours must meet the Continuing Education Content Standards established by NAPA.