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ADVISORY SERVICES GENERAL DISCLOSURES

Ally Invest Advisors Inc. ("Ally Invest") is an SEC Registered investment advisor. Financial advisory services are only provided to investors who become an Ally Invest Client (“Client”) pursuant to a written account agreement which investors are urged to read and carefully consider in determining whether such agreement is suitable for their individual facts and circumstances. For detailed information pertaining to Services, Fees, and Risks please refer to our Wrap Fee Program Brochure.

Brokerage accounts are serviced by Ally Invest Securities LLC (“Ally Invest Securities”) and advisory client account assets are held in the custody of Apex Clearing Corporation, members FINRA and SIPC. Disclosures and notices pertaining to your relationship with Ally Invest Securities include, among others, Account Protection and Order Routing and Payment for Order Flow. Please read all disclosures and notices pertaining to your relationship with Ally Invest Securities at: https://www.ally.com/invest/disclosures/.
Ally Invest Advisors and Ally Invest Securities are wholly owned subsidiaries of Ally Invest Group Inc. Ally Invest Group is a wholly owned subsidiary of Ally Financial Inc.

Ally Invest managed portfolios are not cash, cash alternatives, or money market funds and should not be viewed as such holdings. Investments are not FDIC Insured; are not guaranteed by Ally Financial Inc. or Ally Bank; and may lose value. All investments involve risk, which may include the loss of income payments as well as some or all principal invested. Past performance does not guarantee future results. Any historical returns, expected returns, or probability projections may not reflect actual future performance. This is not an offer or solicitation of an offer in any jurisdiction where Ally Invest is not authorized to conduct investment advisory business. Ally Invest does not provide financial planning services to individual investors.

Ally Invest employs a disciplined investment process based on Modern Portfolio Theory which seeks to construct a set of efficient portfolios for different levels of risk appetite utilizing Exchange Traded Funds (“ETF”). The investment strategies are diversified across a broad mix of asset classes, geographies, major market sectors and segments. Asset allocation and diversification does not necessarily eliminate the risk of experiencing investment loss. Ally Invest does not warrant or guarantee its process will lead to success.

ETFs are only one type of securities product, and Ally Invest generally does not make other types of securities products available that an investor may wish to consider as part of his or her overall financial plan. Other ETFs or investment products may provide different performance. Investment advice is limited to accounts managed by Ally Invest and does not take into consideration accounts held outside of Ally Invest. Ally Invest does not take a client's personal tax situation into consideration when managing portfolios. We recommend that our clients consult with their tax advisor.

Ally Invest’s goal-based questionnaire is designed to determine a Client’s general attitude towards investment risk and financial needs to reach a stated general investment goal. Ally Invest does not base its recommendation on goals or financial needs not disclosed by the Client through this questionnaire. The accuracy of the data provided by a Client is important to Ally Invest’s investment recommendation; however, Ally Invest will not be required to verify any information received from a Client, and Ally Invest is expressly authorized to rely on such information provided by a Client.

The securities utilized in Ally Invest Managed Portfolios are comprised of ETFs or other publicly registered funds, which generally are registered investment companies under the Investment Company Act of 1940. Ally Invest’s asset selection process seeks to identify ETFs which exhibit high liquidity, low expenses, and low tracking error. Ally Invest’s selection process does not guarantee the quality of a particular ETF or that it will 1) be profitable, 2) properly track any comparable index, 3) trade in a liquid fashion, or 4) trade at or above its publicly-posted net asset value. Ally Invest reserves the right to change the selection of ETFs it recommends at any time. Changes in the selection of ETFs employed by Ally Invest services may result in the sale of existing holdings and could be subject to additional tax liability.

Before you invest, you should carefully review and consider the investment objectives, risks, charges and expenses of each ETF that are to be used for the Client within Ally Invest managed portfolios. The risks applicable to any portfolio are those associated with its underlying securities. ETF trading prices may not necessarily reflect the net asset value of the underlying securities. You are able to review and download the ETF product descriptions via the Securities and Exchange Commission’s (SEC) website.

ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track. An ETF typically includes embedded expenses that may reduce its net asset value, and therefore directly affect its performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. These expenses may include management fees, custodial fees, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. In addition, certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable. Other considerations may include the supply and demand in the market for either the ETF and/or for the securities held by the ETF, which may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF.

Ally Invest monitors the execution quality of transactions to ensure that Clients receive the best overall trade execution pursuant to regulatory requirements. Ally Invest makes no representations or warranties regarding the execution quality of orders placed with our brokerage partners. Be aware that in some limited instances it may be difficult or impossible to trade ETF shares or the securities held by an ETF. This liquidity risk may be caused by numerous factors, including but not limited to: 1) extreme market volatility, 2) a decision by exchange participants to withhold some or all of their quoted market bids, 3) exchange technical issues or exchange closure, 4) delisted or halted securities, and/or 5) a position that is large relative to the average daily trading volume of the security.

As part of transferring an external brokerage account to Ally Invest (i.e. ACAT), we will sell your account unless you let us know in advance. Liquidating your transferred account may cause, among other things, realized capital gains or losses in specific securities, surrender fees, and redirection of declared dividends or distributions. Also be aware that selling down securities prior to transfer could subject you to the same risks.