Vident Investment Advisory, LLC

Vident Investment Advisory, LLC is an investment advisory firm established in March 2014, providing services since December 2014. The firm specializes in providing a range of investment solutions primarily as a sub-adviser to exchange-traded funds (ETFs), pooled investment vehicles, and separately managed accounts (SMAs). For SMAs, VIA offers discretionary sub-advisory services for laddered bond portfolios and equity strategy SMAs. The minimum investable assets required for SMAs are $300,000 for laddered bond portfolios and $500,000 for equity portfolios, with negotiable minimums. VIA charges asset-based fees for its services, with fee schedules varying based on the type of SMA. The firm does not participate in wrap fee programs and does not charge performance-based fees. VIA acts as a fiduciary and exercises investment discretion for client accounts, with a focus on best execution and client interests. The firm does not engage in principal trades with clients and has established a Code of Ethics to ensure ethical conduct. Proxy voting for ESMA accounts is overseen by VIA's affiliate, VA, with a focus on maximizing value for clients. VIA does not have custody of client assets and does not require prepayment of fees. The firm reviews client accounts regularly to assess investment objectives and diversification.