Item 5 Additional Compensation 22


4. A. Firm Description and Principal Ownership: Performa Limited (US), LLC, a Delaware limited liability company, was founded in April 2010 as Ansonborough Capital Management, LLC (“ACM”) On July 1, 2012, the Company name changed to Performa Limited (US), LLC in recognition of its affiliation with P.R.P. Performa Ltd, an investment management firm located in Hamilton Bermuda and licensed to conduct investment business with the Bermuda Monetary Authority (“BMA”)

Performa registered as an investment adviser with the SEC in July 2012. Performa provides fixed income and equity investment management, sub-advisory and advisory services to institutions, mutual funds and other investment vehicles including Bermuda based mutual funds registered with the BMA.

On December 31, 2014, Performa and related persons acquired Blue Granite Capital, LLC, an investment advisory firm.

On December 31, 2017, Performa sold Blue Granite Capital back to its original owner, Scott Shubert.

Performa is a privately held company and with no other indirect ownership. Performa is 100% owned by its key employees and its founder, David T. Kilborn, CFA. Mr. Kilborn holds a majority of the Company’s Interest directly, while key employees hold their interests via a limited partnership in accordance to the Firm’s Equity Plan that was established August 21, 2013.

Performa manages each of its clients’ accounts in accordance with pre-determined guidelines and restrictions, either on a fully discretionary basis or on an advisory basis, as established in the applicable agreement with such client.

4. B. Investment Management and Advisory Services:

Performa concentrates its business on its core competencies: portfolio management and asset allocation. Performa offers investment management services as well as advisory services as indicated below.

Fixed Income: Performa provides continuous fixed income, investment management advice on a fully discretionary basis to institutions, U.S. private funds and non-US (offshore) registered investment vehicles as well as separately managed accounts. The Company, or an affiliated entity, acts as the General Partner to such U.S. private fund vehicles. Performa also offers sub-strategies through the use of sub-investment advisers. Performa offers the following styles of investment grade fixed income management: Money Market of Cash Equivalents: Performa manages portfolios with guidelines that mirror those for typical registered money market funds and those that have relaxed guidelines to allow for additional yield possibilities. Low Duration Fixed Income: Performa manages shorter portfolios with the goal of capital preservation first and foremost, and then for yield and capital appreciation. This strategy combines high quality Corporate bonds with other sectors of the fixed income market including, but not limited to: Asset Backed Securities, Residential and Commercial Mortgage Backed Securities, Agencies, and Treasuries.

Intermediate Fixed Income: Performa manages medium term portfolios against a variety of generally accepted benchmarks and includes the same fixed income sectors as its Low Duration portfolios. Certain portfolios allow the use of derivatives within portfolios in this strategy.

High Yield Fixed Income: Performa offers a high yield fixed income strategy through the use of a sub-investment adviser. The strategy invests primarily in high yield debt instruments of U.S. and non-U.S. issuers.

Sector Strategies: Performa may manage fixed income portfolios invested only in certain individual sectors of the fixed income market such as Corporate bonds.

Customized or Non-Discretionary Portfolios: Within Performa’s fixed income business, clients may require strategies outside of the usual strategies managed by the Company. The scope of services provided to such clients may include the following:

- Economic Analysis; - Fundamental research; - Ongoing portfolio analysis that can include sector and duration recommendations; - Implementation of recommendations if discretionary or execution assistance if non- discretionary; - Individual security analysis and buy/sell recommendations; - Other assistance with regulatory reporting for regulated clients; and/or Asset/Liability advice.

Equities:

Performa utilizes equities within client portfolios using an internal passive strategy and sub-investment advisers.

Performa offers the following styles of equity management:

US Passive Equity (“Passive Equity Strategy”): Performa manages Core U.S. Equities seeking to perform at the level of the broad U.S. equity market, as measured by the S&P 500, over market cycles with lower downside capture in negative market environments. The U.S. Passive Equity strategy centers around holding exchange traded index securities such as Exchange Traded Funds (“ETFs”) focused on long-term capital appreciation and dividend income. The U.S. Passive Equity strategy holdings will be the S&P500, or equivalent, strategy ETF and, when appropriate, other ETFs that represent other sectors or groups generally within the U.S. equity markets. Within the Fund’s diversified total equity market allocations, the Passive Strategy is used as the broad market anchor to allow exposure to more specialized and potentially higher volatility/ less correlated equity sub-strategies. Mid-Cap Equity Strategy: Performa offers a mid-cap equity strategy through the use of a sub-investment adviser. The strategy invests primarily in diversified portfolio of equity securities of companies with mid- market capitalizations.

Small-Cap Equity Strategy:

Performa offers a small-cap equity strategy through the use of a sub-investment adviser. The strategy invests primarily in equity securities of companies with market capitalizations of less than $5 billion.

Asset Allocation:

The Firm’s Asset Allocation strategies may also invest in vehicles such as mutual funds, private funds or exchange traded/index funds that are managed by sub-advisors. When using ETFs or Index Funds, the Company uses its internally focused macro analysis and research to rotate between different equity styles and markets

4. C. Asset Allocation and Advisory Services:

Performa provides Asset Allocation recommendations to clients of which it manages a portion of the client’s assets. If necessary, Performa will work with the client to determine suitable external managers that are complimentary to the strategies managed internally by Performa. Performa personnel use their experience as portfolio managers and previous experience as sell- side traders to evaluate other managers and strategies for suitability as well as other techniques from a quantitative perspective.

4. D. Individual Client Restrictions and Needs:

Performa’s management of client portfolios is generally on a fully discretionary basis, but each client has unique investment objectives and portfolio guidelines with the ability to impose their own investment restrictions

4. E. Wrap Fee Programs: Performa does not participate in wrap fee programs. 4. F. Assets Under Management: As of December 31, 2019 Performa managed approximately $1,972,004,487 in client assets on a fully discretionary basis and $0 in client assets on a non-discretionary basis. please register to get more info

Performa charges management fees based on a percentage of assets under management. The following description sets forth typical management fees charged to various types of clients. Performa’s fees are generally payable quarterly in arrears and may be prorated for those periods during a client’s initial funding as well as termination. The basic oversight and asset allocation fee associated with Performa’s management is: Oversight & Advisory Fee 0.300% per year on the first $20 million; 0.275% per year on the next $30 million; 0.225% per year on the next $50 million; 0.200% per year over $100 million.

Performa’s fees are negotiable and may vary based on the type of client and the level of services requested. The amount of customization within the client relationship, meetings, structure of the investments, restrictions, client account size and other factors as number and frequency of reports and client meetings, individual investment guidelines and restrictions, account size and type of client entity (i.e., educational institution).

Performa does not have physical custody of any client assets. Clients are responsible for making arrangements with their custodians and for paying their custodian’s fees and expenses.

Performa’s investment management fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Please review Item 12 of this Brochure, for details pertaining to Brokerage Practices. Fees are billed directly to the client.

Funds and Sub-Advisory

Fund Fees and Sub-Advisory Fees are negotiated on a case-by-case basis as the scope and responsibility can vary greatly. The advisor receives an invoice for payment and is encouraged to review the invoice to ensure the proper fee calculation has been made.

Performa does not accept compensation for the sale of securities or other investment products. please register to get more info

Performa does not participate in any performance fee arrangement with any clients. Performa does not participate in side-by-side management of assets. please register to get more info

Performa provides or may provide investment management and services to institutional clients such as other investment management firms (on a sub- advisory basis), banks, insurance companies, foreign registered mutual funds, domestic or foreign private funds, pension and profit sharing plans, retirement and benefit plans for unions (Taft-Hartley plans), public funds, endowments, foundations, trusts, government-sponsored entities, educational and healthcare facilities such as colleges and hospitals and other types of corporate clients. The minimum account size depends on the strategy and account characteristics. Performa may accept or retain clients whose accounts are based on our sole discretion. Typically, the Firm believes that its investment management style suits portfolios generally $1,000,000 or greater for Asset Allocation Clients and $25,000,000 or greater for fixed income separate accounts. Certain private funds have lower minimum sizes for participation. please register to get more info

8. A. Methods of Analysis

Performa’s investment ideas may be generated from a wide variety of sources, including internally generated fundamental, technical analysis, economic and strategic analysis. Performa also may use research issued by other independent research firms, and industry contacts such as other investors, dealers, other originators, bond and stock traders and brokers.

Performa’s investment process generally starts with a macro view of the global economy and rate cycles. Performa employs four pillars of macro research to formulate the policy which then drives duration and sector allocation decisions:

- Macro-economic environment and prospects - Monetary policy - Structural and secular changes - Market flows and technical analysis

Performa then uses a bottom up, security level analysis to determine the best holdings within each sector. Buy/sell decisions include fundamental research on individual issuers when necessary.

Performa designs and manages portfolios so that capital preservation can be an important goal. The key macro decisions may bear as much weight in performance as security selection at any time.

8. B. Investment Strategies Fixed Income Strategy Descriptions Intermediate Fixed Income Strategy The primary objective of the intermediate fixed income strategy is to provide long term capital appreciation through an optimized mix of investment grade securities across international markets and while maintaining a relatively short duration that will not exceed seven years. This strategy focuses on particular investment guidelines in attempting to achieve its objective. There can be no assurance that the objective will be achieved. The intermediate fixed income strategy is an active strategy and only available to qualified purchasers. This strategy may be available through a private equity offering. The risks involved in investing in a private equity are numerous and are outlined in the fund’s Confidential Private Offering Memorandum, Limited Partnership Agreement and Subscription Agreement. Performa personnel will only introduce or recommend this strategy as appropriate. Low Duration Strategy The primary objective of the low duration strategy is to preserve principal consistent with the generation of investment income. The strategy invests primarily in U.S. government and U.S. corporate bonds of the investment grade quality. This strategy is currently only available to offshore investors and not available for purchase to United States persons. Additional information regarding suitable investors and the risks involved in this strategy are outlined in the Confidential Memorandum.

High Yield Strategy

The overall investment objective is to achieve, through the individual Class Funds, an above average rate of total return while attempting to limit investment risk by investing in a diversified portfolio of fixed income securities. This strategy invests primarily in high yield debt instruments of U.S. and non-U.S. issuers. An instrument is considered “High-Yield” if is rated below investment grade by nationally recognized statistical rating organizations (NRSRO) such as S&P, Moody’s or Fitch. The High Yield market is sensitive to cyclical economic events and therefore, the Manager will change the average credit quality and duration risk from time to time as deemed appropriate. This strategy focuses on particular investment guidelines in attempting to achieve its objective. There can be no assurance that the objective will be achieved. The strategy is an active strategy and only available to qualified purchasers. This strategy may be available through a private equity offering. The risks involved in investing in a private equity are numerous and are outlined in the fund’s Confidential Private Offering Memorandum, Limited Partnership Agreement and Subscription Agreement. Performa personnel will only introduce or recommend this strategy as appropriate.

Cash Management Strategy

The overall investment objective is to achieve income while attempting to limit investment risk by investing in a diversified portfolio of cash and near cash instruments. This strategy focuses on particular investment guidelines in attempting to achieve its objective. There can be no assurance that the objective will be achieved. The money market strategy is an actively managed strategy focused on investing principally in cash and near cash instruments. This strategy is currently only available to offshore investors and not available for purchase to United States persons. Additional information regarding suitable investors and the risks involved in this strategy are outlined in the Confidential Memorandum. Equity Strategy Descriptions: Passive Equity Strategy The goal of the Passive Equity Strategy is to perform at the level of the broad U.S. equity markets, as measured by the S&P 500, over market cycles with lower downside capture in negative market environments. This strategy is designed to provide passive, large market capitalization U.S. equity market exposure, while at times, employing an active management component focused on downside protection. The Passive Equity Strategy centers around holding exchange traded index securities such as Exchange Traded Funds (“ETFs”) focused on long- term capital appreciation and dividend income. For downside protection, the strategy may be less than 100% invested in equity markets. This may take the form of holding cash reserves or through an equivalent utilization of equity index futures and options on futures to decrease the percentage exposure within the strategy. Mid Cap Equity Strategy The primary objective of the account is to produce a total return over time which exceeds that of the Russell Midcap Index, net of investment management fees, over a full market cycle. The portfolio will seek to achieve its goal primarily through investments in a diversified portfolio of equity securities of companies with midmarket capitalizations. The strategy is an active strategy and only available to qualified purchasers. This strategy may be available through a private equity offering. The risks involved in investing in a private equity are numerous and are outlined in the fund’s Confidential Private Offering Memorandum, Limited Partnership Agreement and Subscription Agreement. Performa personnel will only introduce or recommend this strategy as appropriate.

Small Cap Equity Strategy

The objective of the Small Cap Equity Strategy is to generate excess return over a full cycle (peak to peak or trough to trough), by applying a disciplined, research-based process to build concentrated portfolios of companies drawn from the most undervalued segment of the market. The sub-investment adviser will consider a security for the Fund based on its price-to- normalized earnings ratio relative to other companies in the universe and in the portfolio. The strategy is an active strategy and only available to qualified purchasers. This strategy may be available through a private equity offering. The risks involved in investing in a private equity are numerous and are outlined in the fund’s Confidential Private Offering Memorandum, Limited Partnership Agreement and Subscription Agreement. Performa personnel will only introduce or recommend this strategy as appropriate.

8. C. Risk of Loss

General Investment Risks: Securities investments are not guaranteed and you may lose money on your investments. Clients or prospective clients should carefully read any offering documentation or other materials relating to an investment for a detailed explanation of the risks associated with an investment.

Risks Relating to Fixed Income Securities: Performa may invest (long or short) in debt instruments or other fixed-income securities of U.S. and non-U.S. issuers, including, without limitation, debt securities issued or guaranteed by the U.S. Government or one of its agencies or instrumentalities and debt instruments issued or guaranteed by other sovereign nations. Fixed- income securities pay fixed, variable or floating rates of interest. The value of fixed- income securities in which Performa invests will change in response to fluctuations in interest rates. In addition, the value of certain fixed-income securities can fluctuate in response to perceptions of credit worthiness, political stability or soundness of economic policies. Fixed- income securities are subject to the risk of the issuer’s inability to meet principal and interest payments on its obligations (i.e., credit risk) and are subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (i.e., market risk). The material risks relating to the significant methods of analysis and investment strategies described above are set forth below: Credit Risk: Debt securities are subject to the risk that an issuer will fail to make timely payments of interest or principal, or go bankrupt, or that the value of the securities will decline because of a market perception that the owner may not make payment on time. The lower the rating of a debt security, the higher its credit risk. Interest Rate Risk: Debt securities will generally lose value if interest rates increase. U.S. Government securities can exhibit price movements resulting from changes in interest rates. Interest rate risk is generally higher for investments with longer maturities or durations. Treasury Inflation Protected Securities (“TIPS”) can also exhibit price movements as a result of changing inflation expectations and seasonal inflation patterns.

Mortgage and Asset Backed Security Risk: Mortgage and asset-backed securities are debt instruments that are secured by interests in pools of mortgage loans or other financial assets. The value of these securities will be influenced by the factors affecting the assets underlying such securities, swings in interest rates, changes in default rates, or deteriorating economic conditions. During periods of declining asset values, mortgage-backed and asset- backed securities may face valuation difficulties, become more volatile and/or illiquid.

Prepayment and Call Risk: When mortgages and other obligations are prepaid and when securities are called, the fund may have to reinvest in securities with a lower yield or fail to recover additional amounts paid for securities with higher interest rates, resulting in an unexpected capital loss.

Foreign Securities Risk: Foreign securities involve special risks such as currency fluctuations, economic or financial instability, lack of timely or reliable financial information and unfavorable political or legal developments and delays in enforcement of rights. These risks are increased for investments in emerging markets.

Below Investment Grade Securities Risk: Below investment grade securities (sometimes referred to as “junk bonds”) involve greater risk of default or downgrade and are more volatile than investment grade securities. Below investment grade securities may also be less liquid than higher quality securities.

Derivatives Risk: Investments in derivatives exposes a client to additional volatility and potential loss. Losses on investments in certain types of derivatives may exceed the initial investment. Foreign Currency Forward Contracts Risk: The technique of purchasing foreign currency forward contracts to obtain exposure to currencies or manage currency risk may not be effective. In addition, currency markets generally are not as regulated as securities markets. Swap Risk: Certain clients may enter into swap agreements, including credit default swaps, for purposes of attempting to gain exposure to a particular asset without actually purchasing that asset, or to hedge a position. Credit default swaps may increase the client’s exposure to credit risk and could result in losses if Performa does not correctly evaluate the creditworthiness of the entity on which the credit default swap is based. Swap agreements may also subject the client to the risk that the counterparty to the transaction may not meet its obligations. Futures Contract Risk: Certain clients may enter into futures contracts. The risks associated with futures include Performa’s ability to manage these instruments, the potential inability to terminate or sell a position, the lack of a liquid secondary market for the client’s position and the risk that the counterparty to the transaction will not meet its obligations. Leverage Risk: Certain transactions and the use of derivatives such as foreign currency forward contracts, swaps and futures may create leveraging risk. Leverage may cause the client’s account to be more volatile than if the client’s account had not been leveraged. This is because leverage tends to exaggerate the effect of any increase or decrease in the value of the client’s securities.

Risks Relating to Equity Market Securities: The Firm may invest portions of client assets directly into equity investments, primarily stocks, or into pooled investment funds that invest in the stock market. As noted above, while pooled investments have diversified portfolios that may make them less risky than investments in individual securities, funds that invest in stocks and other equity securities are nevertheless subject to the risks of the stock market. These risks include, without limitation, the risks that stock values will decline due to daily fluctuations in the markets, and that stock values will decline over longer periods (e.g., bear markets) due to general market declines in the stock prices for all companies, regardless of any individual security’s prospects. please register to get more info

Performa has no reportable disciplinary events to disclose. please register to get more info

David T. Kilborn, Managing Member, Chief Investment Officer, Chief Executive Officer & President of Performa, acts as the Chief Investment Officer and a Director for Performa’s affiliated firm, P.R.P. Performa, Ltd., as well as a Director of certain Bermuda domiciled mutual funds sponsored by that company. He is also a member of one or more investment partnerships including the General Partnerships that manage the private investment vehicles that use Performa as their investment manager.

The Company is affiliated with P.R.P. Performa Ltd., a Hamilton, Bermuda based investment management firm that manages fixed income portfolios for Captive insurance and Re- insurance companies in Bermuda and other foreign countries that allow for the formation of Captive and Re-insurance companies. P.R.P Performa Ltd. also manages various Bermuda domiciled mutual funds that are registered with the Bermuda Monetary Authority (“BMA”). P.R.P. Performa Ltd. is licensed to conduct investment business by the Bermuda Monetary Authority. While not anticipated, if the activities of Mr. Kilborn on behalf of Performa Limited (US), LLC or the Company’s affiliation with P.R.P. Performa Ltd. result in any conflicts of interest with respect to Performa, its subsidiary or any of its clients, Mr. Kilborn will recuse himself from any decision where such conflict arises. please register to get more info

Personal Trading
Performa has adopted a written Code of Ethics and other policies and procedures which set forth standards of conduct and compliance with federal securities laws, including with respect to personal trading activities of Performa principals and employees. Performa considers Managing Members that are active in the day-to-day management of the Company and all employees to be “Access Persons” and subjected to all policies and procedures. Performa will provide a copy of its Code of Ethics to any client or prospective client upon request. It is Performa’s policy that no Access Person may usurp any investment opportunity which may be appropriate for one or more client accounts without first presenting the opportunity to Performa’s management, particularly where there is limited availability for participation in the opportunity.

The Gifts and Entertainment Policy - Establishes limitations on the acceptance of gifts and/or entertainment by Access Persons, as well as reporting requirements and enforcement procedures. All Access Persons are prohibited from accepting gifts that exceed $100 from the same party during the same calendar year.

Insider Trading - Performa has adopted an Insider Trading Policy in accordance with Advisers Act Section 204A which establishes policies and procedures to prevent the misuse of material information by Access Persons. Performa and its related persons may, from time to time, come into possession of material nonpublic and other confidential information, which, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, Performa and its related persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is an advisory client. Accordingly, should such persons acquire possession of material nonpublic or other confidential information with respect to any company, they are prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law.

Political Contributions - It is Performa’s policy to prohibit political contributions at all levels of the government including to officials and candidates for offices as it presents potential conflicts of interests or could be construed as an attempt to influence.

Personal Trading - In accordance with the Advisers Act, specifically Rule 204A-1, and the 1940 Act, specifically, Rule 17j-1(b)(1), Performa has adopted a strict Code of Ethics that addresses personal and professional conflicts of interest, prohibits certain types of personal securities transactions, and is designed to avoid perceived or actual conflicts and prevent front running and possible insider trading abuses. The Code of Ethics also establishes reporting requirements and enforcement procedures. Procedures with reporting requirements are fulfilled by Access Persons through reporting to designated compliance personnel within the Compliance Department. All Access Persons are required to comply with Federal Securities Laws. All Access Persons are required to immediately report any violation of the Code of Ethics to the Board of Managers and Compliance Department. All Access Persons are required to initially/quarterly/annually submit the appropriate information, material, and documentation regarding all personal trading. Each Access Person is required to direct each brokerage firm or bank at which such Access Person maintains a securities related account which the Access Person has direct or indirect beneficial interest in, to send duplicate copies of each person’s confirmations and statement to the Compliance Department.

All Access Persons are required, in accordance with firm policies, to pre-clear and/or report personal transactions in their accounts. (Certain mutual funds, cash/cash equivalents, indexes and government related securities may be exempt.)

Market timing and late day trading detailed by the SEC are not permitted.

Short term trading is discouraged.

Access Persons may be restricted from specific styles of trading such as good-until- canceled orders, and may be restricted from specific types of investments such as initial public offerings (“IPOs”) and private placements.

The Compliance Department reviews personal activity daily/quarterly/annually to determine if any individual violations occurred during that period.

Performa shall maintain records under the conditions described in Rule 31a-2 under the 1940 Act and Rule 204-2 of the Advisers Act that shall be available for examination by representatives of the SEC.

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Performa requires discretionary clients to provide us written authority to select a broker- dealer in connection with transactions effected on behalf of such client. Performa generally has authority to select broker-dealers and to negotiate transaction related charges including commissions to be paid.

When placing portfolio transactions and negotiating commission rates, Performa will seek to obtain the best execution for its clients, taking into account the following factors:

(i) Availability of electronic trading platforms as the most desirable form for executions for a particular market; (ii) The availability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); (iii) The operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; (iv) The financial strength, integrity and stability of the broker; (v) The reputation of the broker; (vi) The firm’s risk in positioning a block of securities; (vii) Efficiency of execution and error resolution; (viii) The quality, comprehensiveness and frequency of available research services considered to be of value, and (ix) The competitiveness of commission rates in comparison with other brokers satisfying Performa’s other selection criteria For discretionary clients, Performa is authorized to pay higher prices for the purchase of securities from or accept lower prices for the sale of securities to brokerage firms that provide it with such investment and research information or to pay higher commissions to such firms if Performa determines such prices or commissions are reasonable in relation to the overall services provided.

Research services furnished by brokers may include written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing or appraisal services; discussions with research personnel; and invitations to attend conferences or meetings with management or industry consultants. Performa is not required to weigh any of these factors equally. Information so received is in addition to and not in lieu of services to be performed by Performa, and no fees are reduced as a consequence of the receipt of such supplemental research information.

Allocation of Trades. Performa may at times determine that certain securities will be suitable for acquisition for its clients. If Performa is not able to acquire the desired aggregate amount of such securities on terms and conditions which Performa deems advisable, Performa will endeavor to allocate in good faith the limited amount of such securities acquired among the various accounts for which Performa considers them to be suitable. In particular, certain situations may arise where securities or other instruments determined by Performa to be suitable for acquisition on behalf of its clients may not be allocable among all clients for a variety of reasons, including, without limitation, restrictions regarding the holders of such securities or instruments, or country-specific or broker restrictions.

Performa may make such allocations among the accounts in any manner which it considers to be fair under the circumstances, including but not limited to, allocations based on relative account sizes, funds available for investment, diversification considerations, the degree of risk involved in the securities acquired, and the extent to which a position in such securities is consistent with the investment policies and strategies of the various accounts involved. All things being equal, Performa will always attempt to allocate on a pro-rata basis.

Aggregation of Orders. Performa may aggregate purchase and sale orders of securities held by its clients with similar orders being made simultaneously for other accounts or entities if, in Performa’s reasonable judgment, such aggregation is reasonably likely to result in an overall economic benefit to the clients based on an evaluation that the clients will be benefited by relatively better purchase or sale prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other factors. In many instances, the purchase or sale of securities for the clients will be affected simultaneously with the purchase or sale of like securities for other accounts or entities. Such transactions may be made at slightly different prices, due to the volume of securities purchased or sold. In such event, the average price of all securities purchased or sold in such transactions may be determined, at Performa’s sole discretion, and the client may be charged or credited, as the case may be, with the average transaction price. Soft Dollar Practices. Performa does not intend to engage in any soft dollar transactions on behalf of its clients please register to get more info

Performa client portfolios are reviewed at a formal Client Management monthly meeting and at the Company’s Investment Policy Group. Both meetings include members of Performa’s portfolio management and client service departments. This review includes a number of assessments for portfolio guidelines, investment and allocation strategy, client changes and cash flow changes along with any other client specific factors. In addition to the weekly meetings, client portfolios are also reviewed on an ad hoc basis via the Firm’s daily investment call.

Other factors that may cause a portfolio review are client contributions or distributions, revised client objectives or changes in law.

Performa provides a variety of reporting to its clients including:

1) Monthly portfolio valuations, performance, activity and cash flow, and factsheets; 2) Quarterly management reports which expand upon the monthly reporting and include investment and market commentary; typically detailing trading, performance, holding and information about market activity; 3) Ad hoc meeting reports; 4) Periodic financial market commentary publication as well as ad hoc client market update communications; and 5) Performa may provide more frequent reporting as requested by a client.

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Additional Compensation. While it does not currently do so, Performa or its affiliates may sell interests in an investment vehicle through broker-dealers, placement agents and other persons (each such person, a “Placement Agent”) and pay a marketing fee or commission in connection with such activities, including ongoing payments. Clients should recognize that the selection of brokers who have referred, or may refer clients, creates a potential conflict of interest between the client’s interest in best price and execution and the adviser’s interest in referrals. Such Placement Agent fees or commissions shall be payable by Performa or its affiliates (either directly or indirectly by offsetting Management Fees owed to Performa), or by the individual investor introduced to an investment vehicle by such Placement Agent (on a fully disclosed basis).

Performa may on occasion enter into solicitation agreements with individuals, financial intermediaries or others who may or may not be affiliated with Performa. All solicitation agreements will comply with Rule 206(4)-3 under the Advisers Act and any other law as applicable. please register to get more info

For separate account clients, Performa does not have physical custody of client securities, cash or any other assets. Each separate account client selects and contracts with a qualified custodian of their choice to custody the assets that the client appoints Performa to manage. Clients should receive at least quarterly statements from the qualified custodian that hold and maintains the client’s investment assets. Performa urges each client to carefully review such statements and to compare such official custodial records to the account statements that are provided by Performa. It is possible our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. please register to get more info

Clients engage Performa to provide discretionary investment management services, in which case Performa places trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Performa usually receives discretionary authority from a client at the outset of an advisory relationship, pursuant to an investment management agreement with the client. Performa’s discretion may be limited pursuant to the terms and conditions of the applicable advisory relationship.

Discretionary authority allows Performa the ability to select the identity and amount of securities to be bought or sold for a client’s account, without contacting the client.

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Performa is not required to take any action or render any advice with respect to the voting of proxies solicited by or with respect to the issuers of securities in which client assets may be invested from time to time. In the event that Performa receives any such proxies, it shall promptly forward them to the relevant client for voting purposes or otherwise cooperate with the client in voting such proxies in accordance with the client’s instructions.

Performa may accept proxy voting responsibility at the request of a Client. Once Performa accepts proxy voting responsibility, generally the Client will be allowed to request to vote their proxies on a particular solicitation and Performa will attempt to comply with the request on a best- efforts basis. The client may request confirmation of proxy voting submissions.

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Performa has no financial commitments or conditions to report that would impede its ability to service its clients. Performa has never been the subject of a bankruptcy proceeding.

Under no circumstances do we require or solicit payment of fees from clients in any amount more than six months in advance of services rendered. Therefore, we are not required to include a financial statement with this brochure. Performa may be deemed to have custody of the assets and securities of any partnership by which it is the sole General Partner even though it is not the qualified custodian. To qualify for an exemption to the custody rule’s surprise exam requirement, Performa has taken the following steps: 1) All transactions and assets in the partnership will be held at a qualified custodian; 2) either Performa or the third party record keeper will send, not less than quarterly, statements to all members participating in the partnership; 3) audited financial statements will be prepared annually by a member of the Public Company Accounting Oversight Board in accordance with “generally accepted accounting principles” and will be distributed to all members of the partnership within 120 days of the end of each fiscal year; and 4) in the event of liquidation of a partnership, Performa will obtain a final audit of the partnership’s financial statements and distribute the financial statements to all partnership investors promptly after completion of the audit.
Other Information – Business Continuity
Performa has a Business Continuity and Disaster Recovery Plan that provides detailed steps to mitigate and recover from issues arising during a natural disaster or any other prolonged absence from normal office life.

Performa has a very nimble and flexible IT environment that allows for simple disaster recovery and business continuity policies and procedures. The goal of Performa's IT environment is to be as cloud based as possible as this provides for a superior disaster recovery and business continuity combined with the flexibility to be able to perform services under any circumstance.

Performa utilizes a team approach to working with clients, so generally a client will have a relationship with more than just one Performa employee. This has been purposely done in order to provide redundancies in the event that a key employee is not available, and we consider this to be a best practice.

Further information can be provided by contacting Kathy Nicholl, Chief Compliance Officer.
Part 2B of Form ADV:
Item 1 – Cover Page
Brochure Supplement
Biographical Information

Performa Limited (US), LLC
960 Morrison Drive, Suite 200
Charleston, SC 29403

Phone: 843-297-4940
Fax: 843-300-1057


March 31, 2020

This brochure supplement is a supplemental to the Performa Limited (US), LLC (“Performa” or the “Company”) brochure and provides biographical information about Managing Member, David T. Kilborn, CFA and key investment personnel, Scott McIntyre, CFA, Jason Golder, Scott Mildrum and Peter Milne, Christopher Kresco and Michael Reavill. You should have received a copy of the Performa brochure. Please contact Kathy Nicholl at [email protected] or (843) 297-4940 if you did not receive Performa’s brochure or if you have any questions about the contents of this supplement. Additional information about David T. Kilborn, CRD# 2314307is available on the SEC’s website at www.adviserinfo.sec.gov.

David T. Kilborn – Managing Member David T. Kilborn, born in 1968, is a Managing Member, Chief Investment Officer, Chief Executive Officer, & President of Performa. He is responsible for the oversight of portfolio management, risk management and trading as well as general management and oversight of Performa. Since June 2009, Mr. Kilborn has periodically worked as a consultant to several investment firms. Since August 2011, Mr. Kilborn has been the Chief Investment Officer and responsible for the oversight for the Fixed Income and Asset Allocation investment process for PRP Performa, Ltd, an affiliated company. He is also a director of certain Bermuda domiciled mutual funds sponsored by that company and a member of one or more investment partnerships. He provided investment consulting services in Fixed Income Trading for LR Burtschy & Co from June 2009 until August 2011. From October 1995 until his decision to leave in October 2008, Mr. Kilborn served as the Chief Investment Officer and a member of the Board of Directors of Dwight Asset Management Co., an investment firm with over $70 billion in assets under management. While at Dwight Asset Management, Mr. Kilborn was responsible for all investment strategies with an emphasis on macro decision making. Mr. Kilborn was involved in managing a variety of fixed income investment products and sectors of the fixed income markets. From 1990 to 1995, Mr. Kilborn held trading and/or sales positions within International and Emerging Markets desks at Manufacturers Hanover Trust, Chemical Bank, Midland Global Markets (HSBC) and Nations Banc Capital Markets.

Mr. Kilborn is a Chartered Financial Analyst and holds a Bachelor of Arts Degree in Economics from Trinity College, which he received in 1990.

Scott M. McIntyre, CFA – Investment Grade Corporate Portfolio Management

Scott McIntyre, born in 1970, joined Performa in August of 2012. Scott is a senior member of the Investment Policy Group and heads investment grade credit. He has been involved in all aspects of the fixed income markets having spent considerable time early in his career as an investment grade and high yield analyst before moving into trading and managing Investment Grade portfolios. Before joining Performa, Scott held the position of Head of Investment Grade Credit at Dwight Asset Management and was a member of firm’s Fixed Income Strategy Team. He also held senior positions at Dwight Asset Management in portfolio management and as a credit analyst. Prior to that, Scott was a credit analyst at Gannett Welsh & Kotler and Loomis Sayles in Boston. Scott holds a M.B.A. in Business Management and B.A. in Political Science from Union College. Scott holds the Chartered Financial Analyst designation and is a member of the CFA Institute as well as the CFA Societies of Vermont and Boston.

Jason M. Golder – Structured Product Portfolio Management Jason Golder, born in 1976, joined Performa in August 2012 as a Senior Portfolio Manager with Structured Product Sector responsibilities and a member of the firm’s Investment Policy Committee. Prior to joining Performa, Mr. Golder served as a fixed income Portfolio Manager for Dwight Asset Management, responsible for over $2 billion in Commercial Real Estate securities. His portfolio management role included the analysis and trading of CMBS for a wide variety of institutional portfolios and funds. Before joining Dwight’s portfolio management unit, Jason began as a quantitative analyst and then moved to managing and trading the firm’s securities lending portfolio. He transitioned to the Structured Product team in 2006 in a role covering residential, commercial and consumer receivables backed securities. In 2008, Mr. Golder became head of CMBS. Prior to moving to Dwight Asset Management in 2002, Jason held positions in credit mitigation, recruitment and sales. He graduated from Middlebury College with a B.A. in Psychology. R. Scott Mildrum – Economic & Macro Quantitative Strategist Scott Mildrum, born in 1984, joined Performa in July 2012, originally focused on Asset Allocation and Portfolio Construction enhancements. He currently concentrates on providing input into the firm’s macro investment policy. Scott previously worked at Dwight Asset Management from 2007 to 2010 as both a Quantitative Analyst and Associate Portfolio Manager running portfolio analytic systems, modeling tactical and strategic interest rate positioning trades as well as risk management monitoring. Scott left Dwight to study Economics at the University of Oregon. Prior to Dwight, he worked at Princeton University as a Data Analyst writing statistical programs and creating and managing databases for various university departmental research projects. Scott holds a Masters in Economics from the University of Oregon as well as B.A.s in Mathematics and Economics from the University of Vermont.

Peter M. Milne – Liquid Product Portfolio Management

Peter Milne, born in 1976, is Performa’s Head of Asset Allocation & Liquid Markets and is a member of the firm’s Investment Policy Group. Peter’s responsibilities include the day- to- day management of the firm’s money market fund and other client liquidity strategies. As Asset Allocation portfolio manager, he is also responsible for managing overall client exposure in accordance with their stated guidelines and positioning within the firm’s asset allocation policies, as well as oversight of trading activity. Peter is a member of Performa’s Investment Policy Group, providing input as a sector portfolio manager. He is also a member of the firm’s Asset Allocation Policy Group. Prior to joining Performa, Peter worked at Dwight Asset Management as a structured products portfolio manager with a particular focus on residential mortgage- backed and asset-backed securities. After Dwight, Peter held positions at The GFI Group as an inter-dealer broker covering MBS, ABS, and CLOs, and more recently at AOC Securities in institutional fixed income sales. Peter received his B.S. degree from the University of Vermont with a major in Finance & Management Information Systems.

Christopher Kresco, CFA – Corporate Credit Analyst

Chris, born in 1972, is a Corporate Credit Analyst primarily responsible for monitoring current fixed income holdings and identifying new investment opportunities while monitoring economic, market and industry trends and fundamentals. He has 20 years of experience in the fixed income markets including significant experience as an investment grade and high yield analyst in a wide range of industries including financials, energy, industrials and materials. Before joining Performa, Chris was a VP, Fixed Income Analyst at Sentinel Asset Management, the investment arm of National Life based in Montpelier, VT. Prior to that, Chris held various analyst positions at KDP Investment Advisory Services, Opus Investment Management and Fleet National Bank, amongst others. Chris holds the Chartered Financial Analyst designation, earned a M.B.A. from Boston College and a B.A. degree from the University of Massachusetts, Amherst. Michael Reavill – Associate Portfolio Manager Mike, born in 1994, is an Associate Portfolio Manager responsible for day-to-day operation of Performa’s cash management vehicles. He also provides quantitative analysis across investment strategies and general support to the investment team. Mike interned with Performa during college from October 2015 to May 2016. He joined Performa full-time as an Operations Data Analyst in 2016 after graduating from the University of Vermont with a B.S. in Business Administration. Mike is a Level III candidate in the CFA program. Item 3 – Disciplinary Information

Advisers are required to disclose any material facts regarding certain legal or disciplinary events that would be material to your evaluation of an adviser; however the supervised persons have no such disciplinary information to report. Item 4 – Other Business Activities No supervised persons are engaged in any other business activities outside of their roles noted above in Item 2 - Educational Background and Business Experience. Item 5 – Additional Compensation There is no other income or compensation to disclose as it pertains to those noted above. please register to get more info