IMPORTANT DISCLOSURE INFORMATION & PRIVACY NOTICE

Duncan Financial Management, Inc. (“DFM”) is a Missouri, Illinois and Florida registered investment adviser headquartered in Fenton, Missouri.   DFM may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. DFM’s web site is limited to the dissemination of general information pertaining to its advisory services, together with access to additional investment-related information, publications, and links.  Accordingly, the publication ofDFM’s web site on the Internet should not be construed by any consumer and/or prospective client as DFM’s solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation, over the Internet.  Any subsequent, direct communication by DFM with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of DFM, please contact the SEC or the state securities regulators for those states in which DFM maintains a notice filing.  A copy of DFM’s current written disclosure statement discussing DFM’s business operations, services, and fees is available from DFM upon written request. DFM does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to DFM’s web site or incorporated herein, and takes no responsibility therefor.  All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.

Please remember that different types of investments involve varying degrees of risk, including the loss of principal, and there can be no assurance that the future performance of any specific investment or investment strategy (including those undertaken or recommended by DFM), will be profitable or equal any historical performance level(s). No investment strategy can guarantee a profit or protect against loss in periods of declining values.  Any reference to protection benefits or lifetime income refer only to fixed insurance products, not securities or investment products.  Insurance and annuity product guarantees are backed by the financial strength and claims-paying ability of the issuing insurance company.

Certain portions of DFM’s web site (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, DFM’s (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date.  Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s).  Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from DFM, or from any other investment professional. DFM is neither an attorney nor an accountant, and no portion of the web site content should be interpreted as legal, accounting or tax advice.

Rankings and/or recognition by unaffiliated rating services and/or publications should not be construed by a client or prospective client as a guarantee that he/she will experience a certain level of results if DFM is engaged, or continues to be engaged, to provide investment advisory services, nor should it be construed as a current or past endorsement of DFM by any of its clients.  Rankings published by magazines, and others, generally base their selections exclusively on information prepared and/or submitted by the recognized adviser.

Each client and prospective client agrees, as a condition precedent to his/her/its access to DFM’s web site, to release and hold harmless DFM, its officers, directors, owners, employees and agents from any and all adverse consequences resulting from any of his/her/its actions and/or omissions which are independent of his/her/its receipt of personalized individual advice from DFM.

PRIVACY NOTICE

Duncan Financial Management, Inc. (referred to as “DFM”) delivers this Privacy Notice initially upon engagement and annually thereafter. We believe it is important that you understand our uses of the information we gather from you. In performing our services for you, we may gather non-public personal information about you: information we may receive from you in our conversations, discussions and interviews; information relating to the services we render for you; information you deliver to us in written or other format; information prepared by and delivered by third parties acting on your behalf. Please be advised that except as stated in this notice we do not disclose any non-public personal information about you to anyone except as permitted by law.   Although we are not currently required to file certain reports with the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”), we have voluntarily decided to assist law enforcement by adopting procedures to detect suspicious activity and potentially make certain reports to FinCEN. Therefore, we may disclose non-public information about you to FinCEN or other government agencies.

It is the policy of DFM to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, services we render to you, information you deliver to DFM, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to you. You agree to permit us to consult with and to provide financial information to your attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, to the extent necessary to help provide service to you.

DFM maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ nonpublic personal information (“information”). These measures include computer safeguards, secure files, and secure building access. Through this policy and its underlying procedures, DFM attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

DFM permits only authorized employees and affiliates who have signed a copy of DFM’s Privacy Policy to have access to client information. Employees violating DFM’s Privacy Policy will be subject to DFM’s disciplinary process. Additionally, whenever DFM hires other organizations to provide services to DFM’s clients, DFM will require them to sign confidentiality agreements and/or the Privacy Policy. DFM’s Privacy Policy remains in effect at all times, even if the client relationship is terminated.

Should you have any questions regarding the above, please contact Jeffrey Duncan, Chief Compliance Officer.

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