SL Advisors, LLC is a limited liability company formed under the laws of the state of New Jersey. The firm has been in business since September 2009. The firm offers portfolio management and investment supervisory services to individuals and charitable organizations. Investment supervisory services are offered through discretionary managed accounts held at a qualified and independent custodian. The firm is owned by Simon A. Lack and Henry A Hoffman.
Mr. Lack retired from JPMorgan in 2009 after 23 years. Most recently, he served as Chief Strategist for JPMorgan Alternative Asset Management, JPMorgan's hedge fund of funds unit. Mr. Lack also ran JPMorgan Incubator Funds I and II, private equity vehicles which provided seed capital to new hedge funds in exchange for equity-like economics. Mr. Lack has been investing in hedge funds for 15 years, having served on JPMorgan's investment committee responsible for investing JPMorgan's proprietary capital, prior to setting up the Incubator Funds. From 1985-99, Mr. Lack ran fixed income trading for JPMorgan. Mr. Lack is a CFA charter holder. Mr. Lack was born in 1962.


Mr. Hoffman joined SL Advisors in 2010 as a research analyst and became a partner in January of this year. Mr. Hoffman is also a CFA. Mr. Hoffman was born in 1983.


The firm offers clients advice on their portfolios, and provides investment supervisory services in the form of separately managed accounts over which the Firm has discretion. The firm provides investment services through five strategies; SL Advisors Hedged Dividend Capture Strategy; SL Advisors Deep Value Equity Strategy; SL Advisors MLP Strategy, SL Advisors High Dividend Low Beta Strategy and SL Advisors Low Beta Long-Short Strategy. Descriptions of each strategy are in Item 8 below. The firm also provides balanced account advice for clients on an individual basis, which may combine the investment strategies listed above or may include other customized strategies consistent with the client's overall objectives. Each client is offered an Investment Policy Statement which outlines the objectives, risks and constraints applicable to that individual client. The firm will honor any reasonable restrictions on investing in certain securities or types of securities imposed by the client in writing. The firm does not currently participate in any wrap fee programs. SL Advisors provides investment advisory or subadvisory services to Registered Investment Companies. SL Advisors manages each Investment Company pursuant to the investment strategy and restrictions described in the prospectus of such Investment Company. SL Advisors does not provide tailored investment advisory services to the individual investors in an Investment Company.

For certain separately managed accounts ("SMAs"), SL Advisors may recommend all or a portion of the investment be placed in an investment company for which SL Advisors serves as portfolio manager. When SL Advisors recommends these investment companies it does not charge a separate management fee for the SMA assets allocated to the investment companies. SL Advisors compensation comes from the investment company.

The firm also publishes a monthly newsletter, a free service to clients and prospects. This newsletter is published on the firm's website as well as distributed via email to clients and others. Further, Mr. Lack publishes an investment blog from time to time, a link to which is provided on the firm's website.


As of January 2, 2020, the firm managed approximately $221,973,783 comprised of 107 discretionary accounts.


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The annual fee for the firm's investment supervisory services is 1% of the market value of each client's account. Fees are charged quarterly in arrears based upon the asset values on the last day of the previous calendar quarter. The first advisory fee will be assessed on a pro-rata basis taking into account the time for which the account was not managed by the firm. Upon termination of a managed account agreement, the client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by client. Fees to the firm are generally not negotiable. The firm, however, has the right to reduce or waive the management fee charged to any client account.


Fees are either automatically deducted from the account, as authorized in writing by the client, or billed at each quarter end. For accounts from which fees are automatically deducted, the quarterly statement provided to the client by the qualified custodian shows fees for services provided. Further, the firm provides the client with copies of invoices on a quarterly basis.


Mutual funds, closed-end funds, and exchange traded funds are among the investment vehicles used, and the investment strategies, objectives and types of securities held by such funds vary widely. In addition to the advisory fee charged by the firm, clients indirectly pay for the expenses and advisory fees charged by the funds in which their assets are invested.


All such funds incur operating expenses in connection with the management of the fund. Clients will incur brokerage and other transaction costs (see Item 12 of this brochure for more information). Investment funds pass some or all of these expenses through to their shareholders (the individual investors in the funds) in the form of management fees. The management fees charged vary from fund to fund. In addition, funds charge shareholders (individual investors in the funds) other types of fees such as early redemption or transaction fees. These charges also vary widely among funds. As a result, clients will still pay management fees and other "indirect" fees and expenses as charged by each mutual fund (or other pooled investment vehicle) in which they are invested. The firm only charges management fees as outlined above.


SL Advisors serves as the investment adviser to a registered investment company. The fees and compensation paid to SL Advisors by an Investment Company are described in such Investment Company's Prospectus. A copy of each Investment Company's Prospectus is available through the SEC's website at www.sec.gov/edgar/searchedgar/companysearch.html. The fees and compensation paid to SL Advisors will be paid by the Investment Company in accordance with SL Advisor's advisory agreement. An Investment Company investor will indirectly bear its pro rata share of the fees, expenses or charges described in the Investment Company's Prospectus. Such fees, expenses and charges include, but are not limited to, fees incurred for legal, audit and custodial services provided to the Investment Company and transactions effected for the Investment Company such as brokerage and execution charges, markups and commissions. Please see the discussion below in "Item 12. Brokerage Practices" for a description of brokerage and execution charges. SL Advisors will not receive sales commissions in connection with sales of interest in an Investment Company.

When SL Advisors recommends investment companies for SMA accounts, for which it serves as portfolio manager, it does not charge a seperate management fee for the SMA assets allocated to the investment companies. SL Advisors compensation comes from the investment company. please register to get more info

The firm does not manage any accounts on an incentive or performance-based fee basis.


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The firm offers investment supervisory services to individuals, registered investment companies, charitable organizations, and other investment advisers. Account minimums are $1,000,000, although in certain cases the firm retains the right to accept lesser amounts.
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The firm uses multiple sources to research potential investments. The firm analyses global economic trends, industry news and political developments to identify promising areas for further research. Individual investments are researched using publicly available information including regulatory filings, annual and quarterly reports, financial statements and other relevant data. The firm typically invests in securities that it believes offer attractive upside potential with acceptable risk. Investments are made in equity and debt securities, depending on the particular strategy and client needs. SL Advisors offers five distinct investment strategies which are described below:

SL Advisors MLP Strategy This portfolio consists of 10-15 investments in Master Limited Partnerships (MLPs) to receive a healthy and growing tax deferred income stream. MLPs are publicly traded interests in energy infrastructure and related assets. They represent direct proportional ownership stakes in the underlying assets rather than securities in a corporation. Historically they have paid regular distributions which have grown with the U.S. economy, and as such they can be suitable for investors seeking income generating investments with a tolerance for equity market exposure. The strategy engages in low turnover so as to minimize transaction costs and benefit from the income tax deferral features of the asset class. MLPs are appropriate for high net worth investors comfortable with receiving a K-1 for each investment rather than a 1099. SL Advisors does not provide tax advice. This strategy is subject to risk of loss through generally lower equity markets or lower prices on equity securities owned.


SL Advisors Low Vol Hedged Strategy An alternative to bonds, this strategy utilizes stocks of stable companies with high dividend yields to generate income with capital appreciation by investing in a diverse, unleveraged, hedged portfolio of U.S. equities. Companies are selected that possess a history of steady earnings growth, attractive dividend yields and are less volatile than the overall market. The long positions are hedged with a short S&P500 position with the objective of making the portfolio beta neutral while still maintaining a net long equity exposure. Historically this strategy has exhibited monthly swings comparable to corporate bonds, and given the relative attractiveness of equities compared with investment grade bonds, it has a more attractive return outlook. This strategy may be considered suitable for a portion of an investor's fixed income allocation. This strategy is subject to risk of loss through lower equity prices on long positions and risk of divergent performance between the long positions and short hedge positions.


SL Advisors Low Vol Long Only Strategy It should be noted, this is the long-only version of our Hedged Dividend Capture Strategy (Long/Short), which has been actively managed and deployed since October 2011. Academic research has shown the Capital Asset Pricing Model (CAPM) fails to explain risk-adjusted returns. Over long periods of time, high beta stocks tend to under-perform and low beta stocks tend to out-perform, on a risk- adjusted basis, which is inconsistent with predicted performance by the CAPM. This strategy allows investors to take advantage of this persistent anomaly. This strategy is subject to risk of loss through generally lower equity markets or lower prices on equity securities owned

Advisory recommendations are based on the client's financial situation at the time the services are provided and are based on financial information disclosed by client to the firm. Clients are advised that certain assumptions may be made with respect to interest and inflation rates and the use of past trends 6

and performance of the market and economy. Past performance is in no way an indication of future performance. Investing in securities involves risk of loss that clients should be prepared to bear. As a client's financial situation, goals, objectives, or needs change, such client must notify the firm promptly.
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Rule 206(4)-4 of the Investment Advisers Act of 1940 requires investment advisers to provide clients with disclosure as to any legal or disciplinary activities deemed material to the client's evaluation of the adviser. Please note, neither the firm nor its personnel have any disciplinary, regulatory, criminal, civil or otherwise reportable history to disclose at this time.
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Simon Lack, the Managing Partner, holds the Series 65 registered investment adviser license. He is also a CFA charter holder, member of the New York Society of Security Analysts, and member of the CFA Society of Naples, Florida.


SL Advisors is the sub-adviser to the Catalyst MLP & Infrastructure Fund, a mutual fund.

SL Advisers owns the rights to the American Energy Independence Index and licenses the rights to Pacer Advisors who in turn is the adviser to the Pacer American Independence Fund, an ETF based on the licensed index.

These relationships do not present a material conflict of interest.
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Personal Trading
The firm invests Simon Lack's personal portfolio in similar strategies to its clients. The firm has adopted a Code of Ethics to specify and prohibit certain types of transactions deemed to create actual conflicts of interest, the potential for conflicts, or the appearance of conflicts.


The firm and its associated persons may trade in the same securities traded for clients. However, it is the policy of the firm not to give preference to orders for the firm and/or personnel associated with the firm regarding such trading. The firm and/or its employees and members may personally invest in the same securities that are purchased for client trading accounts and may own securities that are subsequently purchased for client accounts. If a security is purchased or sold for client accounts and the firm and/or its employees or members on the same day, the firm and/or its employees or members will pay or receive the same price as the client account, or the client account will receive the more favorable price. If purchased or sold on different days, it is possible that the firm and/or employees' or members' personal transactions might be executed at more favorable prices than were obtained for clients.


The firm and/or its employees and members may buy or sell different investments, based on personal investment considerations, which the firm may not deem appropriate to buy or sell for clients. It is also possible that the firm and/or its employees and members may take investment positions for their own accounts that are contrary to those taken on behalf of clients. The firm and/or its employees and members may also buy or sell a specific security for their personal account based on personal investment considerations aside from company or industry fundamentals, which are not deemed appropriate to buy or sell for clients. This can occur when securities that are not suitable for clients at the time of purchase (e.g., speculative stocks, micro-cap stocks, penny stocks), are purchased by the 7

firm and/or its employees and members. If these securities subsequently appreciate, these personal transactions could be viewed as creating a conflict of interest. Conversely, the firm and/or its employees and members may liquidate a security position that is held both for their own account and for the accounts of firm clients, sometimes in advance of clients. This occurs when personal considerations (i.e., liquidity needs, tax-planning, industry/sector weightings) deem a security sale necessary for individual financial planning reasons. If the security subsequently falls in price, these personal transactions could be viewed as a conflict of interest. The firm will provide a copy of its Code of Ethics to any client or prospective client upon request.
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The firm is not obligated to obtain the best net price or lowest brokerage commission on any particular transaction. Rather, applicable law requires investment managers to use their reasonable best efforts to obtain the most favorable execution for each transaction executed on behalf of client accounts. Therefore, the firm evaluates brokerage services offered on the basis of some or all of the following criteria:


•Execution capability
•Transaction fees and charges
•Effective communications
•Distribution capabilities
•Use of electronic efficiencies
•Whether the broker follows a particular security
•Custodial capabilities and costs
•Ability to execute and settle trades efficiently
•Block trading and block positioning capabilities
•Willingness to execute related or unrelated difficult transactions
•Order of call
•Availability of securities to borrow for short trades
•Trade error policies and practices
•Client reporting capabilities
•Financial stability
•General reputation

Based upon an evaluation of some or all of these factors, the firm may execute client trades through broker-dealers that charge fees that are higher than the lowest available fees. The firm may select broker-dealers whose fees may be greater than those charged for similar investments if the firm determines that brokerage services and research materials provided by that broker-dealer warrant the payment of higher fees. The firm may aggregate orders of more than one client if it is determined that aggregation is in the best interests of the clients. Trade aggregation is usually sought to obtain lower commissions and costs or a better transaction price. The firm does not aggregate securities transactions for client accounts unless it believes that aggregation is consistent with its duty to seek best execution and is consistent with the investment objectives and guidelines for the client accounts participating in the trade.


When orders are aggregated, the price paid by each account is the average price of the order. Transaction costs are allocated to each client on a pro rata basis, based upon the ratio of the amount of particular issue of securities allocated to the account to the overall amount of that issue purchased. It is the firm's policy that trades are not allocated in any manner that favors one group of similarly- situated clients over another. Client transactions may be aggregated according to custodial relationship in consideration of execution charges that may be imposed if trades are directed to a non-custodial broker-dealer for execution. Aggregated trades placed with different brokers may be priced differently.
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The firm generally executes trades through Charles Schwab, with whom clients also custody assets. The firm may also recommend that clients hold accounts with other broker-dealers, as appropriate, based on the client's specific needs. Not all advisers recommend the use of a particular broker-dealer. By directing brokerage to Charles Schwab, the firm may be unable to achieve most favorable execution of client transactions, and this practice may cost the clients more money. Further, the firm permits clients to direct the firm to place transactions with another brokerage firm of a client's choosing.
If the firm is so directed, the client should note that the firm may be unable to achieve most favorable execution of client transactions. Directing brokerage may cost the client more money, since the client may pay higher brokerage commissions because the firm may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices.


The firm does not participate in any soft dollar arrangements.
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Simon Lack is the sole reviewer of accounts. Portfolio reviews take place monthly or more frequently as needed. Individual security positions are assessed continuously. The firm writes a monthly newsletter and publishes research on the internet via a blog linked on the firm's website.
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The firm may pay referral fees to third parties for client referrals. These fees are paid solely by the firm and are not paid by the client, nor do such fees affect the fees paid by clients to the firm. The firm does not have any solicitor relationships with third parties at this time.
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Other than the client authorized direct deductions of fees from accounts, the firm does not maintain nor accept custody of client funds or securities. Clients will receive account statements from the custodian and are encouraged to review such statements carefully.


Each Investment Company has made arrangements with qualified custodians as disclosed in the relevant Prospectus. please register to get more info

Clients authorize the firm to have discretion over which securities to buy and sell for client accounts, the amounts of securities to be bought and sold, the broker or dealer to be used for execution, and the commission rates to be paid to a broker or dealer for such execution. Clients will generally execute a limited power of attorney with Charles Schwab to authorize the execution of trades. Clients will also sign an investment management agreement granting the firm investment discretion. Typically, investments will be in publicly traded equities, exchange traded funds, closed end funds and mutual funds, although other individual equity and debt securities may be used. Investment guidelines and/or limits will be agreed with each client in its Investment Objective and Investment Guidelines.


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It is firm policy not to vote proxy solicitations received on behalf of clients from the issuers of securities held in client accounts. All such solicitations can be forwarded to client for voting upon receipt of a client request. Clients will receive voting materials directly from the broker-dealer and/or the transfer agent of record. Clients may contact firm President Simon Lack with questions about a particular solicitation.
The proxy voting guidelines for Registered Investment Company clients can be found in the respective statement of additional information and other similar documents. please register to get more info

Pursuant to Rule 206(4)-4 of the Investment Advisers Act of 1940, investment advisers are required to disclose certain information about their business practices that might serve as material to the client's decision in choosing an investment adviser. As of the date of this filing, the firm does not require the pre-payment of fees of more than $500 six months or more in advance, or maintain any financial hardships or other conditions that might impair its ability to meet its contractual obligations to clients. The firm has not been the subject of a bankruptcy petition at any time.

Item 19 Requirements for State Registered Advisers
As previously mentioned in Item 3 of this brochure, the firm and its personnel are not subject to any derogatory information relative to their status as fiduciaries. The firm and its personnel do not maintain any relationships or other arrangements with any issuer of securities or similar entity. For further information regarding firm personnel, please see the attached Form ADV Part 2B, brochure supplements.
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