Compliance Disclosure

Rockwood Investment Counsel, LLC complies with all the composite construction requirements of the Global Investment Performance Standards (GIPS®).  Rockwood’s policies and procedures are designed to calculate and present performance in compliance with the GIPS standards.

GIPS is a set of standardized, industry-wide ethical principles that guide investment firms on how to calculate and present their investment results to prospective clients.  Therefore giving investors the transparency they need to evaluate and compare investments products.

Small Cap Core/Value Equity Composite – Annual Disclosure Presentation

* Beginning March 15, 2012, gross-of-fees returns do not reflect the deduction of any expenses, including trading costs and are supplemental to net returns.
** The net 1.0% fee returns are presented as supplemental information
*** 2009 represents 10 months of performance starting 2/28/2009. 2009 Index return for 10 months is that of the Russell 2000 Value Index.
N.A.1 – Information is not statistically meaningful due to an insufficient number of portfolios in the composite for the entire year.
N.A.2 – The three-year annualized standard deviation measures the variability of the composite and the benchmark returns over the preceding 36-month period. The three-year annualized standard deviation is not presented for 2009 through 2011 due to less than 36 months of composite and benchmark data.

Rockwood Small Cap Core/Value is comprised of portfolios invested in U.S. equities which have a market capitalization greater than $200 million and less than $3.5 billion at cost. For comparison purposes this composite is measured against the Russell 2000 Value Index.   Presently, there is a $100,000 minimum account size for this composite. Before 2014 there was no stated minimum account size for this composite.   The Small Cap Core/Value Equity Composite was created March 1, 2009.

Rockwood Investment Counsel, LLC (“RIC”) claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. RIC has been independently verified for the periods March, 2009 through December, 2015.

Verification assesses whether (1) the firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the firm’s policies and procedures are designed to calculate and present performance in compliance with the GIPS standards. The Small Cap Core/Value Equity composite has been examined for the periods March, 2009 through December, 2015. The verification and performance examination reports are available upon request

Rockwood Investment Counsel, LLC is a privately owned limited liability company headquartered in San Diego, CA. RIC is registered as an investment adviser with the State of California.   The firm’s list of composite descriptions is available upon request.

Results are based on fully discretionary accounts under management. Past performance is not indicative of future results.

The U.S. Dollar is the currency used to express performance. Returns are presented gross and net of fees and include the reinvestment of all income. Net of fee returns presented above are calculated using a highest fee of 2.2% applied monthly and a model fee of 1.0% applied monthly. All fee accounts pay a fee based on a percentage of assets under management. Other than brokerage commissions this fee includes investment management, portfolio monitoring, consulting services, and in some cases, custodial services. Beginning March 15, 2012 wrap/bundled fee accounts make up 100% of the composite. Wrap fee schedules are provided by independent wrap sponsors and are available upon request from the respective wrap sponsor. Policies for valuing portfolios, calculating performance, and preparing compliant presentations are available upon request.

The investment management fee schedule for Small Cap Core/Value will be 1%. Actual investment advisory fees incurred by clients may vary.

 

Mid-Cap Core/Value Equity Composite – Annual Disclosure Presentation

* Beginning March 15, 2012, gross-of-fees returns do not reflect the deduction of any expenses, including trading costs and are supplemental to net returns.
** The net 1.0% fee returns are presented as supplemental information
*** 2009 represents 10 months of performance starting 2/28/2009. 2009 Index return for 10 months is that of the Russell Mid Cap Value Index.
N.A.1 – Information is not statistically meaningful due to an insufficient number of portfolios in the composite for the entire year.
N.A.2 – The three-year annualized standard deviation measures the variability of the composite and the benchmark returns over the preceding 36-month period. The three-year annualized standard deviation is not presented for 2009 through 2011 due to less than 36 months of composite and benchmark data.

Rockwood Mid Cap Core/Value is comprised of portfolios invested in U.S. equities which have a market capitalization greater than $3.5 billion and less than $15 billion at cost. Presently, there is $100,000 minimum account size for this composite.   Before 2014 there was no stated minimum account size for this composite.   The Mid Cap Core/Value Equity Composite was created March 1, 2009.

 Rockwood Investment Counsel, LLC (“RIC”) claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. RIC has been independently verified for the periods March, 2009 through December, 2015.

Verification assesses whether (1) the firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the firm’s policies and procedures are designed to calculate and present performance in compliance with the GIPS standards. The Mid Cap Core/Value Equity composite has been examined for the periods March, 2009 through December, 2015. The verification and performance examination reports are available upon request

Rockwood Investment Counsel, LLC is a privately owned limited liability company headquartered in San Diego, CA. RIC is registered as an investment adviser with the State of California. The firm’s list of composite descriptions is available upon request.

Results are based on fully discretionary accounts under management. Past performance is not indicative of future results.

The U.S. Dollar is the currency used to express performance. Returns are presented gross and net of fees and include the reinvestment of all income. Net of fee returns presented above are calculated using a highest fee of 2.2% applied monthly and a model fee of 1.0% applied monthly. All fee accounts pay a fee based on a percentage of assets under management. Other than brokerage commissions this fee includes investment management, portfolio monitoring, consulting services, and in some cases, custodial services. Beginning March 15, 2012, wrap/bundled fee accounts make up 100% of the composite. Wrap fee schedules are provided by independent wrap sponsors and are available upon request from the respective wrap sponsor. Policies for valuing portfolios, calculating performance, and preparing compliant presentations are available upon request.

The investment management fee schedule for the Mid Cap Core/Value is 1%. Actual investment advisory fees incurred by clients may vary.