Description of our Advisory Firm Periope, LC is a registered investment adviser based in St. George, Utah. We are organized as a limited liability company under the laws of the State of Utah. We have been providing investment advisory services since 2006. We are owned by Claude J. Gubler. Currently, we offer the following investment advisory services, which are personalized to each individual client:
•Selection of Other Advisers
•Portfolio Management Services
•Pension Consulting Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Periope, LC and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. The use of these terms is not intended to imply that there is more than one individual associated with our firm.
Description of Advisory Services Selection of Other Advisers As part of our investment advisory services, we may recommend that you use the services of a third party money manager ("MM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we will recommend that you engage a specific MM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the MM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the MM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
As a part of this advisory service, we will meet with you to gather information about your financial circumstances and objectives. After helping to identify your investment objectives, rate of return requirements, and risk tolerance, we may develop a financial plan customized to your individual circumstances. You may implement our portfolio recommendations by utilizing our institutional asset management and manager selection services. We will, at your request, assist you in establishing an investment account with these service providers. We will continue to consult with you on a regular basis to advise you on issues such as account performance, and suitability of the investment strategy in meeting your independent goals and objectives.
Should you choose to implement our recommendations, we suggest that you work closely with your attorney, accountant, insurance agent, and/or stock broker. Implementation of recommendations is entirely at your discretion. You are under no obligation to act on our recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement them through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm you choose.
5 The Asset Management Programs we use are provided by SEI Investments Company ("SEI") and are listed below with an outline of how they are designed. We recommend Asset Management Programs solely on a non-discretionary basis. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. If you choose to engage an Asset Management Program offered by SEI, they may require you grant them discretion to invest and rebalance your investments. For additional information on SEI programs, please refer to their Form ADV.
SEI Management Program 1. Determine the investor's risk profile and investment objectives. We will assist you in determining your investment objectives, investment time horizon, and risk profile by means of an interview process and the completion of a questionnaire. 2. Set a relevant asset allocation policy for you. You agree to one or many mutual fund asset allocations or separate account (individual securities) models. You may also purchase individual mutual funds without choosing one of the asset allocation models. If you so choose, automatic rebalancing to model allocation and recommended model allocation changes may be available. 3. Diversify among asset classes and styles. The investment managers of the underlying mutual funds are selected by SEI Financial Management Corporation. SEI utilizes independent, institutional investment firms. The managers are monitored by SEI to ensure that their investment styles and performance remain consistent with the objectives of the mutual funds. 4. Rebalance your portfolio. Rebalancing maintains the proper allocation to each asset class in the model. Rebalancing occurs automatically if the underlying mutual funds deviate from the prescribed quarterly allocation by greater than a 2% variance (3% for tax managed accounts). Rebalancing occurs quarterly with no transaction fees. 5. Report results. SEI Trust Company (a subsidiary of SEI Financial Corporation) acts as a transfer agent and custodian for your account. SEI Trust Company provides reporting services including consolidated monthly statements, quarterly performance reports, and year-end tax reports. We participate in the Tax-Controlled Program sponsored by SEI Investments Management Corporation ("SIMC"). To participate in the Program, our firm, SIMC and you will execute a tri-party agreement (hereinafter a "Tax-Controlled Agreement") providing for the management of certain of your assets in accordance with the terms thereof. Pursuant to a Tax-Controlled Agreement, you will appoint us as your investment advisor to assist you in selecting an asset allocation strategy, which would include the percentage of your assets allocated to designated portfolios of separate securities (each, a "Separate Account Portfolio") and may include the percentage of assets allocated to a portfolio of mutual funds sponsored by SIMC or an affiliate thereof. You appoint SIMC to manage the assets in each Separate Account Portfolio in accordance with a strategy selected by you together with us. SIMC may delegate its responsibility for selecting particular securities to one or more portfolio managers. The Program seeks to manage taxes within each Separate Account Portfolio through an individually managed U.S. equity and/or laddered municipal bond component(s) within the structure of a globally diversified portfolio in order to meet your long-term goals of managing taxes while controlling risk.
We also participate in the Managed Accounts Program sponsored by SIMC. SIMC will have complete investment authority with respect to the Managed Accounts assets in order to carry out the strategy selected. SIMC may adjust the allocation of the account quarterly to ensure that the mix reflects the objectives of the chosen strategy. The Managed Accounts and SEI Funds are administered, distributed, and in some cases advised by SIMC or its affiliates. SIMC's investment authority is effective until changed or revoked in writing.
6 SIMC will provide you with monthly account statements, quarterly performance reports, and an annual tax report. You will receive shareholder communications (including proxy materials) from the SEI Funds, their service providers or custodians. Unless directed otherwise by you or our firm, SIMC will vote or direct the portfolio Sub-Advisor(s) to vote proxies and receive all shareholder communications with respect to the Managed Account assets.
SIMC uses sub-advisors, either directly or through mutual funds or other pooled investment vehicles managed by such firms, to select individual securities. The sub-advisors are selected based on SIMC's manager research process. SIMC uses proprietary databases and software, supplemented by data from various third parties, to perform qualitative and quantitative analysis of money managers. The qualitative analysis focuses on the manager's investment process, personnel, and performance. Qualitative analysis identifies the sources of a manager's return relative to a benchmark. SIMC uses proprietary performance attribution models as well as models developed by BATTA, Wilshire, and others in its manager research process. In general, multiple sub-advisors are employed in each style or asset class.
Each sub-advisor's characteristics and performance are closely evaluated by SIMC as part of the portfolio management process. A benchmark is established for each sub-advisor, and their industry exposures and performance are compared to the benchmark on a weekly basis. SIMC regularly performs due diligence

reviews of all sub-advisor's personnel organization, investment process and performance. Sub-advisors may be replaced as a result of SIMC's due diligence reviews.
For those accounts, which imply the "manager of managers" structure, SIMC has the ultimate responsibility for the investment performance of the investment vehicles due to its responsibility to oversee the sub-advisors and recommend their hiring, termination and replacement.
SIMC has the authority to determine the securities to be bought or sold in the Managed Account. These decisions will be made in accordance with the strategy chosen by you and our firm.
For additional information and fee schedules on all SEI programs, SEI Trust Company, please refer to their Form ADV.
Portfolio Management Services We offer non-discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non- discretionary basis.
If you engage us for portfolio management services, we may invest your assets according to one or more model portfolios. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may set reasonable restrictions on the specific holdings or allocations within the model, and the types of securities that can be purchased in the model. You must provide these restrictions to our firm in writing.
As a part of this advisory service, we will meet with you to gather information about your financial circumstances and objectives. After helping to identify your investment objectives, rate of return requirements, and risk tolerance, we may develop a financial plan customized to your individual circumstances. We will continue to consult with you on a regular basis to advise you on issues such as account performance, and suitability of the investment strategy in meeting your independent goals and objectives.
7 Should you choose to implement our recommendations, we suggest that you work closely with your attorney, accountant, insurance agent, and/or stock broker. Implementation of recommendations is entirely at your discretion. You are under no obligation to act on our recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement them through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm you choose.
Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents.
General - Advisory Services to Retirement Plans and Plan Participants As disclosed above, we offer various levels of advisory and consulting services to employee benefit plans ("Plan") and to the participants of such plans ("Participants"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan are described above, and in the service agreement that you have previously signed. Our compensation for these services is described below, at Item 5, and also in the service agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. Status 8 Our firm is registered as an investment adviser under the laws of the state of Utah and we represent that we are not subject to any disqualification as set forth in Section 411 of ERISA. In performing our services, we are acting as a fiduciary of the Plan as defined in Section 3(21) under the Employee Retirement Income Security Act ("ERISA") for purposes of providing non-discretionary investment advice only. Wrap Fee Programs We do not participate in any wrap fee program.
Types of Investments We primarily offer advice on ETFs and mutual funds. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of January 17, 2024 we provide continuous management services for $124,920,593 in client assets on a non-discretionary basis.
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