Information About Trades Executed Through Broker-Dealers Other Than Schwab in the Managed Account Select® and Managed Account Connection® Programs

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

April 1, 2018

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 ServicesTM 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.

Manager Name Investment Strategy Name Dollar Weighed Percentage Additional Cost Incurred by of Client Trades "Traded Clients Participating in those Away"1 in 2017 Trades2 in 2017 AllianceBernstein L.P. AllianceBernstein Tax Aware 60% $0 Fixed Income Portfolio

Atlanta Capital Management Atlanta High Quality 66% $0 Company, LLC Small/Mid-Cap Core (closed)

Atlanta Capital Management Atlanta High Quality Small- 56% $0 Company, LLC Cap (closed)

Atlanta Capital Management Calvert/Atlanta Socially 16% $0 Company, LLC Responsible Equity

BlackRock Investment BlackRock Core Bond - SMA Fixed Income: 100% $0 Management, LLC Mutual Funds: 0%

BlackRock Investment BlackRock Global Dividend Fixed Income: 100% $0 Management, LLC Balanced SMA Equities: 0%

Breckinridge Capital Breckinridge Interm 100% $0 Advisors, Inc. Sustainable Tax-Efficient SMA

Breckinridge Capital Breckinridge Long- 100% $0 Advisors, Inc. Intermediate Municipal Bond

Cambiar Investors, LLC Cambiar International ADR 7% 7 bps

Chandler Asset Chandler 0-12 Yr Corporate 100% $0 Management, Inc. Bond Ladder

Chandler Asset Chandler 0-6 Yr Corporate 100% $0 Management, Inc. Bond Ladder

Chandler Asset Chandler Short-Term Bond 100% $0 Management, Inc. SMA

Charles Schwab Investment TPI Balanced Income - 32% 0 - 2 cps Advisory, Inc. Conservative4

Charles Schwab Investment TPI Balanced Income 32% 0 - 2 cps Advisory, Inc. Strategy4

Charles Schwab Investment TPI Dividend Growth Strategy 32% 0 - 2 cps Advisory, Inc. (K-1 generating)4

Charles Schwab Investment TPI Dividend Growth Strategy 32% 0 - 2 cps Advisory, Inc. (non K-1 generating)4

Manager Name Investment Strategy Name Dollar Weighed Percentage Additional Cost Incurred by of Client Trades "Traded Clients Participating in those Away"1 in 2017 Trades2 in 2017 Charles Schwab Investment Windhaven Diversified 97% 0 - 1 cps Advisory, Inc. Aggressive4

Charles Schwab Investment Windhaven Diversified 97% 0 - 1 cps Advisory, Inc. Conservative4

Charles Schwab Investment Windhaven Diversified 97% 0 - 1 cps Advisory, Inc. Growth4

Cincinnati Asset Cincinnati Investment Grade 100% $0 Management Inc Corporate Bonds

Eagle Asset Management, Eagle Asset Management 100% $0, except for Electronic Inc. High Quality Taxable Platform Trades (Market Axess: 1.3 bps; Trade Web: 1bps; TMC $0.10 - $10 per bond on Muni and $0.50 - $1 on Corporate and Agency Bonds Eagle Asset Management, Eagle Asset Management 100% $0, except for Electronic Inc. Strategic Income Portfolio Platform Trades (Market Axess: 1.3 bps; Trade Web: 1bps; TMC $0.10 - $10 per bond on Muni and $0.50 - $1 on Corporate and Agency Bonds Eagle Asset Management, Eagle Asset Mgmt Strategic 100% $0, except for Electronic Inc. Income Port with Muni Platform Trades (Market Axess: 1.3 bps; Trade Web: 1bps; TMC $0.10 - $10 per bond on Muni and $0.50 - $1 on Corporate and Agency Bonds Eaton Vance Management Eaton Vance 1-10 Yr 100% $0 Corporate Bond Ladder

Eaton Vance Management Eaton Vance 1-5 Yr Corporate 100% $0 Bond Ladder

Eaton Vance Management Eaton Vance 3-7 Yr Corporate 100% $0 Bond Ladder

Eaton Vance Management Eaton Vance 5-10 Yr 100% $0 Corporate Bond Ladder

Eaton Vance Management Eaton Vance TABS 1-14 Yr 100% $0 Municipal Bond Ladder

Eaton Vance Management Eaton Vance TABS 1-14 Yr 100% $0 Municipal Bond Ladder-CA

Eaton Vance Management Eaton Vance TABS 1-8 Yr 100% $0 Municipal Bond Ladder

Manager Name Investment Strategy Name Dollar Weighed Percentage Additional Cost Incurred by of Client Trades "Traded Clients Participating in those Away"1 in 2017 Trades2 in 2017 Eaton Vance Management Eaton Vance TABS 1-8 Yr 100% $0 Municipal Bond Ladder-CA

Eaton Vance Management Eaton Vance TABS 3-12 Yr 100% $0 Municipal Bond Ladder

Eaton Vance Management Eaton Vance TABS 3-12 Yr 100% $0 Municipal Bond Ladder-CA

Eaton Vance Management Eaton Vance TABS 5-15 Yr 100% $0 Municipal Bond Ladder

Eaton Vance Management Eaton Vance TABS 5-15 Yr 100% $0 Municipal Bond Ladder-CA

GW&K Investment GW&K Balanced Income Fixed Income: 100% $0 Management, LLC Strategy with Municipals Equities: 0%

GW&K Investment GW&K Corporate Bond 100% $0 Management, LLC Opportunities Strategy

GW&K Investment GW&K Municipal Bond 100% $0 Management, LLC Strategy

GW&K Investment GW&K Short-Term Taxable 100% $0 Management, LLC Bond Strategy

Invesco Advisers, Inc. Invesco International ADR 76% 3 cps Growth SMA (closed)

JPMorgan Investment JPMorgan Intermediate-Term 100% $0 Management Inc. Municipal Bond

JPMorgan Investment JPMorgan International Core 12% 8 bps Management Inc. ADR (plus 0-5 cps conversion fee) Lazard Asset Management Lazard Emerging Markets Foreign securities: 90- Foreign securities: LLC Equity Select ADR3 100% 3 cps (plus -5 to +4 cps)

US securities: 40% US securities: 0 - 4 cps Lazard Asset Management Lazard Global Equity Income Foreign securities: 90- Foreign securities: LLC ADR3 100% 3 cps (plus -5 to +4 cps)

US securities: 40% US securities: 0 - 4 cps Lazard Asset Management Lazard Global Equity Select Foreign securities: 90- Foreign securities: LLC ADR3 100% 3 cps (plus -5 to +4 cps)

US securities: 40% US securities: 0 - 4 cps Lazard Asset Management Lazard International Equity Foreign securities: 90- Foreign securities: LLC Select ADR3 100% 3 cps (plus -5 to +4 cps)

US securities: 40% US securities: 0 - 4 cps

Manager Name Investment Strategy Name Dollar Weighed Percentage Additional Cost Incurred by of Client Trades "Traded Clients Participating in those Away"1 in 2017 Trades2 in 2017 Legg Mason Private Portfolio ClearBridge Appreciation 59% 1.17 cps Group, LLC

Legg Mason Private Portfolio ClearBridge Mid-Cap Portfolio 55% 0.02 cps Group, LLC

Legg Mason Private Portfolio ClearBridge Multi-Cap Growth 6% 0.5 cps Group, LLC ESG

Legg Mason Private Portfolio Legg Mason Global Value 52% 0.84 cps Group, LLC ADR Balanced

Legg Mason Private Portfolio Western Asset Current 100% $0 Group, LLC Market Muni

Madison Investment Madison Intermediate Fixed 100% $0 Advisors, LLC Income

Neuberger Berman Neuberger International Core 4% 8 bps Investment Advisers LLC ADR (plus -5 cps to 4 cps ADR conversion fee) Neuberger Berman Neuberger Socially 1% 8 bps Investment Advisers LLC Responsive Equity (plus 5 cps ADR conversion fee) Neuberger Berman Neuberger Short Core 100% $0 Investment Advisers LLC Municipal Bond

New York Life Investment MacKay Shields Convertibles 65% $0 Management LLC SMA

NGAM Advisors, L.P. Natixis/Loomis Sayles Core 46% $0 Total Return3

Nuance Investments, LLC Nuance Mid-Cap Value 1% $0

Nuveen Asset Management, Nuveen Intermediate-Term 100% 1 - 10 bps LLC Municipal Bond

Nuveen Asset Management, Nuveen Limited-Maturity 100% 1 - 10 bps LLC Municipal Bond

Nuveen Asset Management, Nuveen Long-Term Municipal 100% 1 - 10 bps LLC Bond

Nuveen Investments Nuveen Mod Aggressive 4% 1 - 10 bps Advisers LLC Portfolio-Muni Bonds

Nuveen Investments Nuveen Mod Conser 19% 1 - 10 bps Advisers LLC Portfolio-Muni Bonds

Nuveen Investments Nuveen Moderate Portfolio- 10% 1 - 10 bps Advisers LLC Muni Bonds

Manager Name Investment Strategy Name Dollar Weighed Percentage Additional Cost Incurred by of Client Trades "Traded Clients Participating in those Away"1 in 2017 Trades2 in 2017 Parametric Portfolio Parametric CC - Fundamental 1% 5 bps Associates LLC International ADR

Parametric Portfolio Parametric CC - MSCI EAFE 1% 5 bps Associates LLC ADR

PIMCO PIMCO 1-12 Year California 100% $0 Municipal Bond Ladder

PIMCO PIMCO 1-12 Year Municipal 100% $0 Bond Ladder

PIMCO PIMCO 1-12 Year New York 100% $0 Municipal Bond Ladder

PIMCO PIMCO 1-18 Year California 100% $0 Municipal Bond Ladder

PIMCO PIMCO 1-18 Year Municipal 100% $0 Bond Ladder

PIMCO PIMCO 1-18 Year New York 100% $0 Municipal Bond Ladder

PIMCO PIMCO 1-6 Year California 100% $0 Municipal Bond Ladder

PIMCO PIMCO 1-6 Year Municipal 100% $0 Bond Ladder

PIMCO PIMCO 1-6 Year New York 100% $0 Municipal Bond Ladder

PIMCO PIMCO Low Duration SMA 100% $0

PIMCO PIMCO Real Return 100% $0

PIMCO PIMCO Total Return 100% $0

Principal Global Investors, Principal Investment Grade 100% $0 LLC Corporate Bond SMA

Principal Global Investors, Spectrum Preferred Securities 85% $0 LLC SMA

Principal Global Investors, Spectrum Preferred Tax 82% $0 LLC Advantaged SMA

RNC Genter Capital RNC Genter Balanced Growth 35% $0 Management with Dividend Income

Manager Name Investment Strategy Name Dollar Weighed Percentage Additional Cost Incurred by of Client Trades "Traded Clients Participating in those Away"1 in 2017 Trades2 in 2017 Seix Investment Advisors Seix High Yield Bond SMA 100% $0 LLC

Stonebridge Advisors LLC Stonebridge Advisors 50% $0 Preferred SMA

Stonebridge Advisors LLC Stonebridge Advisors 50% $0 Preferred Tax Advantaged SMA Thornburg Investment Thornburg International 19% 5 cps Management, Inc. Growth ADR Strategy - Wrap3

Wells Fargo Funds Wells Fargo CoreBuilder 48% $0 Management, LLC Municipal Income

1 Except where indicated, the dollar-weighted percentage of client trades "Traded Away" reflects the dollar amount of trades executed for all Schwab clients invested in the strategy through broker-dealers other than Schwab divided by the total dollar amount of trades executed for those clients and includes only "program" or "model" level trades, as opposed to trades placed for a specific account or accounts (such as when a client invests in or withdraws from the strategy). For example, if a Manager placed $1000 of equity trades for an Investment Strategy during the time period specified, $ 500 of which were with broker-dealers other than Schwab, they would have a 50% dollar weighted percentage of client trades “traded away”.

2 Additional cost incurred by clients is stated in average cents per share (“cps”) unless otherwise indicated. In some instances (generally for securities executed outside the U.S. and Canadian markets), the additional costs are expressed in basis points (“bps”), so that, for example, 10 bps would be equal to 0.1% of the cost. For foreign securities, additional expenses such as exchange fees, taxes, ADR conversion fees, and currency conversion costs may be incurred. Note these may be, but are not always, disclosed as additional cost. For fixed income securities, additional costs such as a markup/markdown or spread may be incurred, but are generally included in the net price and may not be disclosed.

3 Investment Stragegy specific information was not available. The information provided is an average of all accounts traded by the Manager.

4 Dollar-weighted percentage of trades done away from Schwab and average additional cost is estimated based on all equity trades across all ThomasPartners Strategies and Windhaven Strategies managed by Charles Schwab Investment Advisory, Inc. (CSIA) and custodied at Schwab, including accounts that are outside of Schwab-sponsored wrap fee programs.