Excessive Trading Policy

ShareBuilder has adopted an Excessive Trading Policy to discourage market timing and excessive trading activity in their funds.

ShareBuilder monitors mutual fund trade activity and strives to prevent an individual from engaging in excessive trading. If it is determined that an individual has engaged in excessive trading, ShareBuilder will restrict the individual from future purchases with the impacted fund family. In general, ShareBuilder defines excessive trading as more than six exchanges within a rolling 12-month period. However, ShareBuilder reserves the right to limit fund trading with respect to any individual, with or without prior notice, if ShareBuilder determines that the individual’s trading activity is disruptive.

Additionally, ShareBuilder’s policy may differ from a mutual fund's excessive/frequent trading policy as defined in the prospectus. In this situation, ShareBuilder will cooperate with the fund family to implement restrictions and/or block future purchases when their stated policy has been violated. All such restrictions will be done in accordance with the directions ShareBuilder receives from the fund or from ShareBuilder’s clearing agent, and may include a permanent purchase restriction in that fund family.