Information about Trades Executed through Broker-Dealers Other than Schwab in the Managed Account Select® and Managed Account Connection® Programs

July 15, 2021

Charles Schwab & Co., Inc. ("Schwab") sponsors the Managed Account Select ("Select") and Managed Account Connection ("Connection") programs (each a "program") in which Schwab-affiliated and non-affiliated asset managers ("Managers") have discretionary authority to trade in enrolled accounts. The asset-based fee that you pay for the program ("Program Fee") covers the cost of commissions and other execution charges for trades executed through Schwab, but not any additional cost, such as a commission or markup, associated with trades placed directly by Managers with other broker-dealers (collectively, "Trading Away," "Trades Away," or other variations thereof).

As set forth in the Schwab Managed Account Services™ Disclosure Brochure, the Program Fee also does not cover mark-ups or mark-downs on fixed income trades, whether they are traded through Schwab or traded away. For fixed income securities, additional costs such as a markup/markdown or spread are generally included in the net price and are not reflected as a separate charge on trade confirmations or account statements.

Some Managers (including without limitation fixed income strategies, Charles Schwab Investment Management, Inc. ("CSIM") for the Windhaven® Strategies, the ThomasPartners® Strategies, Wasmer Schroeder™ Strategies, and certain types of USAA Managed Portfolios – UMP® program beginning in May 2020 when the UMP program moved onto the Connection program, and including Managers with certain equity strategies, especially small-cap or preferred strategies) execute most or all of their program trades by Trading Away. Managers may have good reasons for Trading Away, such as to meet their obligation to achieve "best execution" for their clients (including clients outside of the programs) – in other words, the best possible trading result, taking into account such factors as price, extra costs, speed and likelihood of execution. Managers may reasonably believe that they are able to achieve better trading results by Trading Away, including better net pricing even with any additional cost associated with Trading Away. In addition to cost considerations, a Manager may consider various other factors as described in their Form ADV brochure ("Brochure"), including the liquidity of the security, the need for timely execution, and other brokerage and research services they receive from that broker-dealer.

Nevertheless, any additional cost of Trading Away is in addition to the Program Fee and, like all costs, will reduce the total return of your account enrolled in the program. The more frequently a Manager Trades Away, the greater the potential additional cost and the greater the potential reduction in total return. Please review this disclosure and additional information about Trading Away and other Manager trading practices in the Schwab Managed Account Services™ Disclosure Brochure in deciding whether to enroll in or remain enrolled in the program. If you have any questions, please contact your Schwab Financial Consultant or another Schwab representative.

The table below describes the self-reported frequency with which Managers engaged in Trading Away, and any additional cost associated with such trades, in program investment strategies during the time periods specified.

The information was provided by the Managers and has not been verified by Schwab. It is historical data about the Manager's past practice, and the Manager may not follow the same practice with the same frequency or resulting cost in the future. Additional information about your Manager's practices may be contained in your Manager's Brochure. If your Manager is not listed below, it is because they reported no Trading Away during the time period(s) shown.

table

Manager Name Investment Strategy Name Dollar-Weighted Percentage of Client Trades "Traded Away"1 in 2020 Average Additional Cost Incurred by Clients Participating in those Trades2 in 2020
AllianceBernstein L.P. AllianceBernstein Tax Aware Fixed Income Portfolio 58% $0
Atlanta Capital Management Company, LLC Atlanta High Quality Select Equity3 18% $0
Atlanta Capital Management Company, LLC Atlanta High Quality Small/Mid-Cap Core (closed)3 74% $0
Atlanta Capital Management Company, LLC Atlanta High Quality Small-Cap (closed)3 33% $0
Atlanta Capital Management Company, LLC Calvert/Atlanta Socially Responsible Equity3 7% $0
BlackRock Investment Management, LLC BlackRock Core Bond - SMA 100% $0
Breckinridge Capital Advisors, Inc. Breckinridge Interm Sustainable Tax-Efficient SMA 100% $0
Breckinridge Capital Advisors, Inc. Breckinridge Long-Intermediate Municipal Bond 100% $0
Brown Advisory LLC Brown Advisory Sustainable Core Bond 100% $0
Cambiar Investors, LLC Cambiar International ADR 64% 7 bps
Chandler Asset Management, Inc. Chandler 0-12 Yr Corporate Bond Ladder 100% $0
Chandler Asset Management, Inc. Chandler 0-6 Yr Corporate Bond Ladder 100% $0
Chandler Asset Management, Inc. Chandler Short-Term Bond SMA 100% $0
Charles Schwab Investment Management, Inc. TPI Balanced Income - Conservative 57% $0.00 - $0.02 cps5
Charles Schwab Investment Management, Inc. TPI Balanced Income Strategy 57% $0.00 - $0.02 cps5
Charles Schwab Investment Management, Inc. TPI Dividend Growth Strategy (K-1 generating) 57% $0.00 - $0.02 cps5
Charles Schwab Investment Management, Inc. TPI Dividend Growth Strategy (non K-1 generating) 57% $0.00 - $0.02 cps5
Charles Schwab Investment Management, Inc. UMP Blend Aggressive 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Blend Conservative 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Blend Moderate 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Blend Moderately Aggressive 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Blend Moderately Conservative 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Blend Very Aggressive 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom 100% Fixed (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom 100% Fixed Tax-Exempt (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USCore+CA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USCore+NY MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USCore+VA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USDiv+NY MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt (USDiv+VA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Aggressive Tax-Exempt(USDiv+CA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Conserv (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv Tax-Exempt (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv Tax-Exempt (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv Tax-Exempt (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv Tax-Exempt (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Conserv Tax-Exempt (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USCore+CA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USCore+NY MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USCore+VA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USDiv+CA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USDiv+NY MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Aggr Tax-Exempt (USDiv+VA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USCore+CA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USCore+NY MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USCore+VA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USDiv+CA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USDiv+NY MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Mod Conserv Tax-Exempt (USDiv+VA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (FI) 100% $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USCore+CA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USCore+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USCore+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USCore+NY MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USCore+VA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USDiv+CA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USDiv+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USDiv+Intl+FI) Equities: 35%
Fixed Income: 100%
Equities: $0.00 - $0.02 cps
Fixed Income: $0
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USDiv+NY MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Moderate Tax-Exempt (USDiv+VA MFs) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Very Aggr (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Very Aggr (USCore+Intl) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Very Aggr (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Very Aggr (USDiv+Intl) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Very Aggr Tax-Exempt (USCore) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Very Aggr Tax-Exempt (USCore+Intl) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Very Aggr Tax-Exempt (USDiv) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP Custom Very Aggr Tax-Exempt (USDiv+Intl) 35% $0.00 - $0.02 cps
Charles Schwab Investment Management, Inc. UMP ETF Aggressive 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Aggressive Tax-Exempt 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Conservative 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Conservative Tax-Exempt 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Moderate 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Moderate Tax-Exempt 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Moderately Aggressive 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Moderately Aggressive Tax-Exempt 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Moderately Conservative 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Moderately Conservative Tax-Exempt 35% $0.00 - $0.01 cps
Charles Schwab Investment Management, Inc. UMP ETF Very Aggressive 35%