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

April 1, 2019

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 through Schwab's Prime Brokerage Services, Step-In Services, or Trade-Away Services (collectively, "Trading Away", "Trades Away", or other variations thereof).

Some Managers 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. Knowing the frequency of and any additional cost associated with Trading Away can be an important factor in deciding whether to enroll in or remain enrolled in the program. You will find additional information about Trading Away and other Manager trading practices in the Schwab Managed Account Services™ Disclosure Brochure. 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 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 Weighed Percentage of Client Trades"Traded Away"1 in 2018  "Traded Away"1 in 2018 Additional Cost Incurred by Clients Participating in those Trades2 in 2018
AllianceBernstein L.P. AllianceBernstein Tax Aware Fixed Income Portfolio 64.72% $0
Atlanta Capital Management Company, LLC Atlanta High Quality Select Equity 17% $0
Atlanta Capital Management Company, LLC Atlanta High Quality Small/Mid-Cap Core (closed) 81% $0
Atlanta Capital Management Company, LLC Atlanta High Quality Small-Cap (closed)  53% $0
Atlanta Capital Management Company, LLC Calvert/Atlanta Socially Responsible Equity 12% $0
BlackRock Investment Management, LLC BlackRock Core Bond - SMA 100%  $0
BlackRock Investment Management, LLC BlackRock Global Dividend Balanced SMA Fixed Income: 100% 
Equities: 0%
$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 18%  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 Advisory, Inc. TPI Balanced Income – Conservative4 39% $0–$0.02 cps
Charles Schwab Investment Advisory, Inc. TPI Balanced Income Strategy4 39% $0–$0.02 cps
Charles Schwab Investment Advisory, Inc. TPI Dividend Growth Strategy (K-1 generating)4 39% $0–$0.02 cps
Charles Schwab Investment Advisory, Inc. TPI Dividend Growth Strategy (non K-1 generating)4 39% $0–$0.02 cps
Charles Schwab Investment Advisory, Inc. Windhaven Diversified Aggressive4 97% $0–$0.01 cps
Charles Schwab Investment Advisory, Inc. Windhaven Diversified Conservative4 97% $0–$0.01 cps
Charles Schwab Investment Advisory, Inc. Windhaven Diversified Growth4 97% $0–$0.01 cps
Cincinnati Asset Management Inc. Cincinnati Investment Grade Corporate Bonds 100% $0
Eagle Asset Management Inc. Eagle Asset Management High Quality Taxable 100% $0, except for Electronic Platform Trades: 
Market Axess: 0-1.5 bps 
Trade Web Corporate Trading: 0.6 bp 
Trade Web Direct: $0.10-$3 per bond 
Liquidnet: 1 bp
TMC: $0.10-$10 per bond on Muni and $0.50-$1 per bond on Corporate and Agency Bonds 
Arbor: $0.03125-$0.0625 per ticket
Eagle Asset Management Inc. Eagle Asset Management Strategic Income Portfolio 100% $0, except for Electronic Platform Trades:
Market Axess: 0-1.5 bps
Trade Web Corporate Trading: 0.6 bp
Trade Web Direct: $0.10-$3 per bond
Liquidnet: 1 bp 
TMC: $0.10-$10 per bond on Muni and $0.50-$1 per bond on Corporate and Agency Bonds 
Arbor: $0.03125-$0.0625 per ticket
Eagle Asset Management Inc. Eagle Asset Mgmt Strategic Income Port with Muni 100% $0, except for Electronic Platform Trades: 
Market Axess: 0-1.5 bps
Trade Web Corporate Trading: 0.6 bp
Trade Web Direct: $0.10-$3 per bond 
Liquidnet: 1 bp
TMC: $0.10-$10 per bond on Muni and $0.50-$1 per bond on Corporate and Agency Bonds 
Arbor: $0.03125-$0.0625 per ticket
Eaton Vance Management Eaton Vance 1-10 Yr Corporate Bond Ladder  100% $0
Eaton Vance Management Eaton Vance 1-5 Yr Corporate Bond Ladder  100% $0
Eaton Vance Management Eaton Vance 3-7 Yr Corporate Bond Ladder  100% $0
Eaton Vance Management Eaton Vance 5-10 Yr Corporate Bond Ladder  100% $0
Eaton Vance Management Eaton Vance TABS 1-14 Yr Municipal Bond Ladder  100% $0
Eaton Vance Management Eaton Vance TABS 1-14 Yr Municipal Bond Ladder-CA  100% $0
Eaton Vance Management Eaton Vance TABS 1-8 Yr Municipal Bond Ladder  100% $0
Eaton Vance Management Eaton Vance TABS 1-8 Yr Municipal Bond Ladder-CA  100% $0
Eaton Vance Management Eaton Vance TABS 3-12 Yr Municipal Bond Ladder  100% $0
Eaton Vance Management Eaton Vance TABS 3-12 Yr Municipal Bond Ladder-CA  100% $0
Eaton Vance Management Eaton Vance TABS 5-15 Yr Municipal Bond Ladder  100% $0
Eaton Vance Management Eaton Vance TABS 5-15 Yr Municipal Bond Ladder-CA  100% $0
GW&K Investment Management, LLC GW&K Balanced Income Strategy with Municipals Fixed Income: 100% 
Equities: 0%
$0
GW&K Investment Management, LLC GW&K Corporate Bond Opportunities Strategy 100% $0
GW&K Investment Management, LLC GW&K Municipal Bond Strategy 100% $0
GW&K Investment Management, LLC GW&K Short-Term Taxable Bond Strategy 100% $0
Invesco Advisers, Inc. Invesco International ADR Growth SMA 70% 20 cps
JPMorgan Investment Management Inc. JPMorgan Intermediate-Term Municipal Bond 100% $0
JPMorgan Investment Management Inc. JPMorgan International Core ADR 7% 8 bps
Lazard Asset Management LLC Lazard Emerging Markets Equity Select ADR 90% Foreign securities: 3cps 
(plus $0.04 credit - 0.05 debit)
Lazard Asset Management LLC Lazard Global Equity Income ADR 90% Foreign securities: 3cps 
(plus $0.04 credit - 0.05 debit)
Lazard Asset Management LLC Lazard Global Equity Select ADR  90% Foreign securities: 3cps 
(plus $0.04 credit - 0.05 debit)
Lazard Asset Management LLC Lazard International Equity Select ADR 90% Foreign securities: 3cps 
(plus $0.04 credit - 0.05 debit)
Legg Mason Private Portfolio Group, LLC ClearBridge Appreciation 45% 1.3 cps
Legg Mason Private Portfolio Group, LLC ClearBridge Mid-Cap Portfolio 64% 0.16 cps
Legg Mason Private Portfolio Group, LLC ClearBridge Multi-Cap Growth ESG 21% 1.53 cps
Legg Mason Private Portfolio Group, LLC Legg Mason Global Value ADR Balanced 68% 0.26 cps
Legg Mason Private Portfolio Group, LLC Western Asset Current Market Muni 100% $0
Madison Investment Advisors, LLC Madison Intermediate Fixed Income 100% $0
Natixis Advisors, L.P. Natixis/Loomis Sayles Core Total Return3 48% $0
Neuberger Berman Investment Advisers LLC Neuberger International Core ADR 1% 8 bps
(plus 5 cps ADR conversion fee)
Neuberger Berman Investment Advisers LLC Neuberger Short Core Municipal Bond 100% $0.10 - $10 per bond
New York Life Investment Management LLC MacKay Shields Convertibles SMA 80% $0
Nuance Investments, LLC Nuance Mid-Cap Value 2% $0
Nuveen Asset Management, LLC Nuveen Intermediate-Term Municipal Bond 100% 1–10 bps
Nuveen Asset Management, LLC Nuveen Limited-Maturity Municipal Bond 100% 1–10 bps
Nuveen Asset Management, LLC Nuveen Long-Term Municipal Bond 100% 1–10 bps
Nuveen Asset Management, LLC Nuveen Mod Aggressive Portfolio-Muni Bonds 12% 1–10 bps
Nuveen Asset Management, LLC Nuveen Mod Conser Portfolio-Muni Bonds 40% 1–10 bps
Nuveen Asset Management, LLC Nuveen Moderate Portfolio–Muni Bonds 22% 1–10 bps
Parametric Portfolio Associates LLC Parametric CC–MSCI EAFE ADR 1% 5 bps
or 0.5 cps
Parametric Portfolio Associates LLC Parametric CC–Russell 1000 1% 5 bps
or 0.5 cps
Parametric Portfolio Associates LLC Parametric CC–Russell 3000 1% 5 bps
or 0.5 cps
Parametric Portfolio Associates LLC Parametric CC–S&P 500 1% 5 bps
or 0.5 cps
PIMCO PIMCO 1-12 Year California Municipal Bond Ladder 100% $0
PIMCO PIMCO 1-12 Year Municipal Bond Ladder 100% $0
PIMCO PIMCO 1-12 Year New York Municipal Bond Ladder 100% $0
PIMCO PIMCO 1-18 Year California Municipal Bond Ladder 100% $0
PIMCO PIMCO 1-18 Year Municipal Bond Ladder 100% $0
PIMCO PIMCO 1-18 Year New York Municipal Bond Ladder 100% $0
PIMCO PIMCO 1-6 Year California Municipal Bond Ladder 100% $0
PIMCO PIMCO 1-6 Year Municipal Bond Ladder 100% $0
PIMCO PIMCO 1-6 Year New York Municipal Bond Ladder 100% $0
PIMCO PIMCO Low Duration SMA 100% $0
PIMCO PIMCO Real Return 100% $0
PIMCO PIMCO Total Return 100% $0
Principal Global Investors, LLC Principal Investment Grade Corporate Bond SMA 100% $0
Principal Global Investors, LLC Spectrum Preferred Securities SMA 90% $0
Principal Global Investors, LLC Spectrum Preferred Tax Advantaged SMA 92% $0
RNC Genter Capital Management RNC Genter Balanced Growth with Dividend Income 35% $0
Sage Advisory Services Ltd Co Sage Advisory ESG Intermediate Fixed Income 100% $0
Seix Investment Advisors LLC Seix High Yield Bond SMA 100% $0
SNW Asset Management, LLC SNW Short-Intermediate Municipal Impact Strategy 100% 1 bps
Stonebridge Advisors LLC Stonebridge Advisors Preferred SMA 50% $0
Stonebridge Advisors LLC Stonebridge Advisors Preferred Tax Advantaged SMA 50% $0
Wells Fargo Funds Management, LLC Wells Fargo CoreBuilder Municipal Income 45% $0