New Century Advisors, LLC (“NCA LLC”), founded in March 2002, provides discretionary fixed-income portfolio management services utilizing separate accounts. The principal owner of the firm is Ellen B. Safir. The headquarters is located at 2 Wisconsin Circle, Suite 940, Chevy Chase, Maryland, 20815. New Century has also opened an office in New Rochelle, NY. The primary functions performed in New York are investment research and trading. NCA LLC offers the following fixed income strategies to clients:  Short Duration Plus Bond – portfolios that seek to preserve and enhance the real value of assets relative to a U.S. benchmark, e.g. Merrill Lynch 1-3 year Treasury.  Core Bond - portfolios that seek to achieve a value-added rate of return relative to a U.S. benchmark, e.g. Bloomberg Barclays Aggregate Index.  Intermediate Core Bond - portfolios that seek to achieve a value-added rate of return relative to a U.S. benchmark, e.g. Bloomberg Barclays U.S. Intermediate Aggregate Index.  US TIPS - portfolios that seek to achieve a value-added rate of return relative to a U.S. benchmark, e.g. Bloomberg Barclays U.S. TIPS Index.  US TIPS 1-5- portfolios that seek to achieve a value-added rate of return relative to a U.S. benchmark, e.g. Bloomberg Barclays 1-5 TIPS Index.  Global Inflation Linked (Hedged and Unhedged strategies) - portfolios that seek to achieve a value-added rate of return relative to a non-U.S. benchmark, e.g. Barclays Global Bond Index.  Multi-Asset Real Return Strategy - portfolios that seek to achieve a value-added rate of 300 basis points above the 12-month Consumer Price Index (CPI) level. NCA LLC tailors its strategies to a client’s needs. NCA LLC works closely with clients to: 1) determine the risk and return objectives, 2) define the asset allocation, and 3) select specific securities and market sectors. NCA LLC assumes discretionary responsibility for all aspects of the day-to-day management and investment of the client’s account. Clients can impose investment guideline restrictions on investing in certain securities or types of securities. On a limited basis, NCA LLC invests client assets in other types of securities, including individual equity securities, options, futures, forward contracts and exchange traded funds (ETFs). As of 12/31/2018, New Century Advisors, LLC managed $ 2,003,634,250 in client assets on a discretionary basis. NCA does not manage assets on a non-discretionary basis. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).  Ellen B. Safir  Nils C. Overdahl please register to get more info

NCA LLC charges a management fee based on assets under management. This fee is payable quarterly in arrears. If a client relationship terminates during the quarter, NCA LLC only bills the client for the time assets were under management. Below are NCA’s basic fee schedules for the investment strategies that it manages. Fee schedules and minimum balances are negotiable in certain circumstances. For accounts that have less than $25 million, the management fee may be higher than the stated schedules. Short –Duration Plus, Core Bond and US TIPS Strategies .35 of 1% (.0035) per annum on the first $25,000,000 .25 of 1% (.0025) per annum on the next $25,000,000 .20 of 1% (.0020) per annum on the next $25,000,000 .15 of 1% (.0015) per annum on the balance There is a minimum annual fee of $87,500 Global Inflation Linked Strategy .40 of 1% (.0040) per annum on the first $25,000,000 .30 of 1% (.0030) per annum on the next $75,000,000 .25 of 1% (.0025) per annum on the next $100,000,000 .20 of 1% (.0020) per annum on the next $100,000,000 15 of 1% (.0015) per annum on the balance There is a minimum annual fee of $100,000 Multi-Asset Real Return Strategy .85 of 1% (.0085) per annum NCA LLC remits a quarterly invoice to the client or client representative and does not directly deduct management fees from its client’s accounts. In addition to NCA LLC’s fee, clients pay brokerage and other transaction costs (as described in Item 12 –Brokerage Practices). Clients also pay charges to financial institutions and other third parties such as custodial fees, charges imposed directly by a mutual fund or exchange traded fund in the account, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. NCA LLC encourages clients to obtain a complete schedule of these fees from their service provider before entering into any engagement. NCA LLC does not receive any portion of these other fees. please register to get more info

New Century Advisors, LLC is generally compensated on the basis of fees calculated as a percentage of a client’s assets under management. In certain instances, however, New Century Advisors, LLC may be compensated under performance based fee arrangements in compliance with SEC Rule 205-3 under the Investment Advisers Act of 1940. Some clients have entered into performance fee arrangements with New Century Advisors, LLC. New Century Advisors offers performance fee arrangements when allowed by law. A performance fee arrangement is a method of compensating an investment adviser on the basis of a share of the gains or appreciation of the assets under management. The fee structure consists of a base fee and a performance fee. For the Intermediate Core Bond Strategy, the annual base fee is negotiable and paid quarterly in arrears. The performance fee, if earned, will be calculated as follows: A hurdle rate (gross of fees) must be achieved to become eligible for an incentive fee payment for the relevant calendar year. If the outperformance exceeds the hurdle rate versus the benchmark for the full calendar year, the incentive fee will equal 10% of the excess return above the hurdle rate, up to a maximum of 10 basis points total incentive fee for any given calendar year. The maximum compensation in any given calendar year would be 25 basis points. In the event that New Century’s net of fee performance lags that of the benchmark for the relevant calendar year, then for purposes of calculating the incentive fee in the following calendar year, the performance hurdle will be revised upward by the amount of underperformance (in basis points). please register to get more info

NCA LLC provides investment advice to banking or thrift institutions, corporate and state pension and profit sharing plans, charitable organizations, and universities. NCA LLC is also a sub-advisor to investment managers and consultants. NCA LLC’s minimum account size is USD $25 million. In certain circumstances, NCA LLC accepts lower account sizes. For certain accounts or strategies managed with less than $25 million, the investment management fee may be higher and a minimum fee may be imposed. Clients may be required to establish foreign settlement accounts at their custodian as well as futures, options, and foreign exchange settlement accounts and capabilities. Additional information, such as Tax Identification Number, Form W-9 or Form W-8BEN, and CFTC Interim Compliant Identifiers (CICI) must be provided prior to trading on behalf of a client’s account, if required. please register to get more info

LOSS
NCA employs a team investment approach and uses both top-down and bottom-up analytics to generate investment ideas. For example, team members evaluate sectors from a fundamental, top-down perspective and also analyze relative value at the security level. Team members also closely follow trades and/or themes for exit and entry points. Investment strategies used to implement any investment advice given include long and short purchases of securities, short-term trading strategies, margin transactions, option writing, including covered options, long and short transactions in cash securities and financial futures. In its analysis, NCA LLC uses financial databases containing current and historical business and financial statistics, financial newspapers and magazines, research materials prepared by others, corporate rating services, annual reports, prospectuses and filings with the SEC, and company press releases. NCA LLC also obtains estimates of future prospects for the economy and various market sectors. In addition to these vendor purchased tools and websites, NCA LLC has developed several proprietary tools, which are used in both relative value analysis and risk management. NCA LLC divides the fixed income market into the six risk factors listed below. NCA LLC evaluates the relative attractiveness of each risk factor and uses valuation models, technical factors and human judgment to create a client portfolio. 1. Interest Rate 2. Term Structure 3. Inflation 4. Volatility 5. Credit 6. Non-U.S. NCA LLC manages risk within a strategy using a proprietary tracking model that calculates portfolio risk. The output lists: 1) the relative risks or tracking error compared to the benchmark, 2) the benefits of diversification, 3) the top portfolio risks, and 4) the distribution of portfolio returns based on history. This output helps NCA LLC see the risks the portfolio contains and how much of the portfolio’s value is at risk. Scenario analysis that includes modeling the risk inherent in potential portfolio changes and size exposures is also conducted. NCA LLC uses derivative instruments to build and manage portfolios. Specifically, NCA LLC purchases treasury, non-US sovereign, and money market futures, as well as exchange- traded options on these futures. NCA LLC believes that derivative instruments increase manager flexibility by allowing the management of exposures at a more granular level. Further, NCA LLC utilizes these instruments to manage interest rate, yield curve, inflation and volatility risk. All of the abovementioned derivatives are highly liquid, exchange-traded instruments and are not subject to counter-party risk. NCA also utilizes forward contracts on currencies. These contracts are highly liquid, but subject to counterparty risk. NCA mitigates the counterparty risk by utilizing more than one counterparty with a minimum credit rating of A-. Investing in securities involves risk of loss that clients should be prepared to bear.
TEM 9 - DISCIPLINARY INFORMATION
NCA LLC and its employees have no legal or disciplinary events to disclose. please register to get more info

NCA LLC does not have any other financial industry activities or affiliations. Eric Patlovich, Portfolio Manager for New Century Advisors, LLC, is a member of the Asset/Liability Committee of the First National Bank in Paxton and Cissna Park State Bank. He is also a member of the board of directors of Agricultural Banking Corp. please register to get more info

TRANSACTIONS AND PERSONAL TRADING
Employees must follow the Code of Ethics and Standards of Professional Conduct promulgated by the CFA Institute. In addition, NCA LLC has a Code of Ethics that all employees must follow. The guiding principal of NCA LLC’s Code of Ethics is that the clients’ interests must always come first. NCA has also adopted procedures regarding the use of material non-public information and procedures to control access to sensitive information, including restricting access to computer files that contain non-public information. NCA LLC employees may invest and transact in certain of the same securities or related securities (e.g., warrants, options, or futures) that it purchases in client accounts. To address this conflict of interest, the code of ethics states:  Employees cannot transact for their own account before considering their fiduciary obligations to their clients.  If an employee knows that NCA LLC is transacting in (or considering transacting in) any security on behalf of a client, the employee may not transact in the same security. In addition, every employee provides NCA LLC with a record of his/her personal securities holdings and transactions. NCA LLC reviews this information and makes sure that an employee’s holdings and transactions do not conflict with the best interests of clients. These records are reviewed by the Chief Compliance Officer for instances of trading practices that harm NCA’s clients, such as scalping, front‐running or taking an investment opportunity from a client for an employee’s own benefit. A copy of the NCA LLC’s Code of Ethics is available to any client or prospective client upon request. Securities purchased for clients will be held in the clients’ names with the issuer and/or with a registered broker/dealer and/or custodian. Neither NCA nor any of its officers or employees has the authority to gain access to client holdings. please register to get more info

NCA LLC seeks to execute client transactions at the most favorable and reasonable commission rates in relation to the benefits the clients’ receive. NCA LLC chooses broker- dealers to execute client transactions based on a number of factors, including: (1) the price of the securities which they offer, (2) the value and quality of their services, and (3) their professional capabilities (including use of capital, clearance and settlement procedures, market familiarity, integrity and reliability). Broker-dealers provide NCA LLC with investment research products and/or services that assist in the investment decision-making process (i.e., soft dollar benefits). Although NCA, LLC does not have any formal soft dollar agreements in place, NCA LLC receives security, sector, market and economic research reports and security pricing services from broker- dealers. This creates a conflict of interest since there is an incentive to select or recommend a broker-dealer that provides these benefits that NCA LLC would otherwise have to pay for. NCA LLC uses these benefits to service all of its client accounts and does not allocate soft dollar benefits to client accounts in proportion to the commissions and fees the accounts generate. The value of any products, research and services given to NCA LLC are not factors considered in selecting broker-dealers and determining the reasonableness of their commissions. Further, NCA LLC does not cause clients to pay commissions (or markups or markdowns) higher than what other broker-dealers charge in return for soft dollar benefits. If it is consistent with best execution and the terms of the client’s agreement, NCA LLC aggregates client transactions. Each client that participates in an aggregated order participates at the average share price for all client transactions in that security on a given business day. In addition, clients share transaction costs pro-rata based on their participation in the transaction. NCA LLC may allocate a partially filled order pro-rata based on the initial allocation, however, if circumstances prevent a pro-rata allocation (minimum purchase requirements, for example), NCA LLC may use additional methods to allocate partially filled orders. If all client accounts receive fair and equitable treatment, NCA LLC could allocate the order on a basis different from the initial allocation. NCA LLC permits clients to direct brokerage. However, NCA LLC only directs brokerage if it is able to obtain the most favorable execution of all client transactions. When a client directs brokerage, it affects NCA LLC’s ability to negotiate commissions and to include the client’s account in aggregated transactions. A client that is not included in an aggregate transaction will not receive benefits such as receiving the average price or transactional costs. On occasion, NCA LLC effects cross transactions between client accounts. This means that NCA LLC arranges for one client to sell securities to another client. NCA LLC effects these cross transactions through a third party broker-dealer who determines the respective purchase and sale price based on the market. please register to get more info

A Portfolio Manager is responsible for performing ad hoc (generally daily) reviews of account holdings, cash in/outflows, investment guideline compliance, sector reviews and daily market movement effects on the strategies. On a monthly basis, a Portfolio Manager or Investment Analyst performs a formal review of the account to ensure that the account is in compliance with the current investment strategy and the account’s investment guidelines. The Portfolio Manager or Investment Analyst documents this evaluation in the client’s file. The evaluation is also reviewed by the Compliance Officer. Clients can elect to receive valuation and transaction statements at the end of each month or quarter. Standard written reports NCA LLC provides to clients include: 1. Current holdings report 2. Monthly transactions report 3. Current Cash Balance report 4. Custodian vs. New Century Advisors Holdings Reconciliation report 5. Monthly performance Clients should also receive monthly or quarterly statements directly from their qualified custodian. Clients should compare the account statements they receive from their qualified custodian with those provided by NCA LLC. please register to get more info

NCA LLC receives soft dollar benefits from broker-dealers, as described in Item 12 above. NCA LLC does not receive any other economic benefit from a non-client for providing investment advisory services. NCA LLC and its employees do not compensate any outside person or third-party firm for client referrals. NCA LLC currently does have arrangements where inside representatives may receive a portion of some or all of their compensation in the form of cash referral fees. These fees are generally calculated as a percentage of the investment advisory fees generated from the assets referred to by the party. please register to get more info

NCA LLC does not have custody of client funds or securities. All clients receive monthly or quarterly account statements directly from their custodian. please register to get more info

NCA LLC only manages client assets on a discretionary basis. Clients specify limitations on NCA LLC’s trading authority in their written investment policy guidelines. Limitations can include, but are not limited to, restrictions on investments of particular issuers, security characteristic/quality limitations, etc. Clients can change these guidelines by providing written notice to NCA LLC. Before NCA LLC provides investment advisory services, clients must sign an investment management agreement and acknowledge mutually agreed upon investment policy guidelines. Clients also sign a limited power of attorney granting NCA LLC trading authority and allowing NCA LLC to access a client’s custodian’s electronic data feed for reporting purposes. Clients may be required to establish foreign settlement accounts at their custodian as well as futures, options, and foreign exchange settlement accounts and capabilities. Additional information, such as Tax Identification Number, Form W-9 or Form W-8BEN, and CFTC Interim Compliant Identifiers (CICI) must be provided prior to New Century Advisors, LLC trading on behalf of a client’s account, if requested. please register to get more info

NCA LLC votes proxies in a manner that serves the best interests of its clients. NCA LLC’s proxy voting policies and procedures address the following common proxy issues: External Auditors, Board of Directors, Proxy Contests and Corporate Defenses, Corporate Governance Provisions, Capital Structure, Executive Compensation/Employee Consideration, State of Incorporation, Mergers and Corporate Restructuring, and Social Issues. Under certain circumstances, NCA LLC refrains from voting proxies taking into consideration, among other reasons, whether clients continue to hold the securities on the voting date and whether NCA LLC believes voting would be inappropriate given the cost of voting the proxy and the anticipated benefit to clients. In addition, upon receiving a written client request, we may vote proxies for that client in a particular manner overall. In a situation where there is a conflict of interest in the voting of proxies, NCA LLC takes steps to ensure that its proxy voting decisions are in the best interest of its clients and are not the product of such conflict. A conflict of interest could occur due to business or personal relationships that NCA LLC maintains with persons having an interest in the outcome of votes. If a client does not authorize NCA LLC to vote client securities, clients will receive their proxies or other solicitations directly from the custodian or transfer agent. Clients may contact NCA LLC directly with any questions about a particular solicitation. Clients can obtain a copy of NCA LLC’s proxy voting policies and procedures upon request. Also upon request, clients can obtain information regarding how NCA LLC voted proxies with respect to their securities. please register to get more info

NCA LLC does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Therefore, we have not included a balance sheet for our most recent fiscal year. In addition, NCA LLC is financially capable of meeting all contractual commitments to its client. NCA LLC has not been subject of a bankruptcy petition. please register to get more info