The Norden Group LLC

The Norden Group LLC is a registered investment adviser based in Provo, UT, established by Garen T. Winn and Seth L. Merrill. The firm offers discretionary portfolio management services, financial planning services, and a Turnkey Asset Management Program in partnership with Townsquare Capital, LLC. Clients have the option for both discretionary and non-discretionary portfolio management services. The firm may use sub-advisers to manage a portion of client accounts on a discretionary basis. The investment strategies include fundamental analysis, long-term and short-term purchases, margin transactions, option writing, ESG criteria, trading, and cash management. The firm charges an annual fee for portfolio management services, a fixed fee for financial planning services, and consulting fees on a case-by-case basis. The firm does not accept performance-based fees or participate in side-by-side management. The firm exercises limited custody over client funds for fee deduction purposes. The firm has a privacy policy in place to protect customer information and restricts access to nonpublic personal information. Clients are provided with regular account reviews and have the option to participate in proxy voting. The firm does not receive compensation for client referrals or engage in directed brokerage practices. For further information, clients can contact the Chief Compliance Officer.