COHEN KLINGENSTEIN LLC

The advisory business primarily focuses on investing in U.S. securities, although it may invest in non-U.S. securities occasionally. The firm expects to limit its advice to the products and accounts listed in the brochure, but may manage additional separate accounts and/or private investment funds in the future. In cases of inconsistency between the governing documents of an account or fund and the brochure, the governing documents will prevail. The advisory business also provides research services, including advice on the value of securities, advisability of purchasing or selling specific securities, and availability of securities. They also furnish analyses and reports concerning issuers, industries, securities, trading markets and methods, changes in accounting practices, economic factors and trends, and portfolio strategy. Additionally, they offer access to research analysis, comparative performance evaluation and technical measurement services, quotation services, and products and other services that assist the firm in carrying out its responsibilities.

The investment strategy for the Diversified Fund focuses on providing diversification and tax efficiency. The fund aims to achieve market-like returns with market-like risk while minimizing taxable gains for investors with limited diversification. This is accomplished through a diversified portfolio of equity securities, primarily U.S. securities but with potential for global investments. The fund seeks to achieve these goals through low fees and tax-deferred contributions. The Firm also employs a general investment strategy of market-like index equities, which may be tailored to individual client needs. This strategy involves long-term purchases and may utilize margin or short sales, but generally avoids futures or derivatives. The Firm does not publicly market this strategy.

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