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SAM - Domicilium Opportunity Zone Fund I

SAM - Domicilium Opportunity Zone Fund I. Stansberry Conference October 2019. Contents. j. What are Opportunity Zones . . . and why you should care. k. How SAM is seizing this opportunity. l. Illustrative projects. How Opportunity Zones came into existence.

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SAM - Domicilium Opportunity Zone Fund I

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  1. SAM - Domicilium Opportunity Zone Fund I Stansberry Conference October 2019

  2. Contents j • What are Opportunity Zones . . . and why you should care k • How SAM is seizing this opportunity l • Illustrative projects

  3. How Opportunity Zones came into existence . . . • Opportunity Zones are a community investment tool established by Congress in the Tax Cuts and Jobs Act of 2017 (the “Trump Tax Cut” law) to encourage long-term investments in low-income urban and rural communities nationwide • They provide a significant tax incentive for investors to re-invest unrealized capital gains into Qualified Opportunity Funds (QOFs) • The Opportunity Zones provision is based on the Investing in Opportunity Act, a piece of legislation that enjoyed broad, bipartisan support and was championed by Senators Tim Scott (R-SC) and Cory Booker (D-NJ) and Representatives Pat Tiberi (R-OH) and Ron Kind (D-WI), along with 100 congressional cosponsors • The concept was originally proposed by Sean Parker’s Economic Innovation Group (EIG) in a 2015 White Paper, “Unlocking Private Capital to Facilitate Economic Growth in Distressed Areas” • It has since gathered endorsements from a wide coalition of investors, entrepreneurs, community developers, economists, and other stakeholders

  4. How Opportunity Zones are defined and located . . . • A “Qualified Opportunity Zone” (QOZ) is a census tract that meets the statutory definition of a “low-income community” • Governors were allowed to designate up to 25% of qualifying census tracts as QOZs • Subsequent approval by the U.S. Treasury was required, but this approval was essentially automatic • IRS Notice 2018-48 (July 9, 2018) includes an official list of all census tracts designated as QOZs • QOZs exist in all 50 states, the District of Columbia, Puerto Rico and the Virgin Islands Source and for more information, including a full list of Opportunity Zones: https://www.cdfifund.gov/Pages/Opportunity-Zones.aspx

  5. Why investors should pay attention • Opportunity Zones are the most significant legal tax arbitrage in a generation . . . • Investors who re-invest capital gains into a Qualified Opportunity Fund can reap the following tax benefits: • A seven-year deferral on the payment of any capital gains tax on the original gain, allowing the gain to compound tax free for an extended period • 15% forgiveness on the original gain – i.e., at year seven, investors pay capital gains tax only on 85% of the original gain, not 100% • Complete tax forgiveness on any gains above the original gain (taxed at year seven) once the investment has been held for 10 years and beyond – i.e., investors pay no capital gains tax at all on the final disposition Forgiveness of gains on appreciation above original gain Capital gains tax due on 85% of original gain Original Gain Invested Original Gain Realized Held for 10 years 180 Days Held for 7 years The above should not be construed as tax advice. Prospective investors are encouraged to discuss these opportunities with their own tax, legal and financial advisers.

  6. Let’s make it concrete and compare re-investing gains in a QOF versus a traditional equity vehicle . . . • Scenario #1: Investor realizes $1 million capital gain on the sale of an investment and re-invests it in a Qualified Opportunity Fund • Scenario #2: Investor realizes $1 million capital gain on the sale of an investment and re-invests it into a portfolio of stocks • Assume the investment compounds at 12% p.a. over a 10 year holding period, and the investor pays the deferred tax due at year 7 • Assume the investment compounds at 12% p.a. over a 10 year holding period and the investor exits at year 10 • At year 10, the original ~$1 million has grown to $3.1 million • The investor will owe $200k in cap gains at inception (20% x $1 million) • The investor pays $170k in tax at year 7, (20% cap gains tax on $850k basis), but no tax on the $3.1 million at disposition • The remaining $800k will be worth ~$2.5 million at year 10, at which point the investor will owe another $500k in cap gains tax • At year 10, the investor’s gain net of tax is ~$1 million ($2.5 million - $500k in tax on disposition - $1 million original basis) • At year 10, the investor’s gain net of tax is $1.93 million ($3.1 million - $170k cap gains tax at year 7 - $1 million original basis) Over 10 years, the tax savings of the OZ investment generate almost ~100% in additional net gains to the investor assuming identical gross rates of compounding The above example is included for illustrative purposes only and each individual’s tax circumstances should be considered prior to making any investment decision. The above should not be construed as tax advice. Prospective investors are encouraged to discuss these opportunities with their own tax, legal and financial advisers.

  7. Key requirements for investors For investors: j Capital Gains Requirement: Only capital gains proceeds, not other assets, are eligible for re-investment into a Qualified Opportunity Fund (QOF) k 180 Day Rule: An investor has 180 days from the date of realization to deploy funds into a QOF. Special and more lenient rules apply if a partner is investing its distributive share of partnership capital gains l 2019 Deadline: To qualify for the full 15% forgiveness on deferred gains at year 7, investors must roll capital gains into a QOF by December 31st, 2019. Congress may act to extend this deadline

  8. Key requirements for Qualified Opportunity Funds For Qualified Opportunity Funds: j Self Certification: A QOF is able to self-certify that it’s a QOF; no approval or action is required by the IRS. A QOF will simply attach Form 8996 to its Federal tax return for all relevant years k 90/10 Rule: The QOF must invest 90% of its assets into “Qualified Opportunity Zone Property” (QOZP). 10% of its assets may be invested or held in any other form • Qualified Opportunity Zone Property includes Qualified Opportunity Zone (QOZ) stock, QOZ partnership interests, or QOZ business property • Even though a Qualified Opportunity Fund may invest in QOZ business property directly, there are compelling reasons to do so indirectly via QOZ stock or partnership interests l Requirements for “QOZ Business Property”: The definition of Qualified Opportunity Zone Business Property (QOZBP) is pivotal regardless whether a QOF invests in such property directly or indirectly. QOZBP must meet three requirements: • Purchase Requirement: The property must be acquired after December 31, 2017 • Use or Substantial Improvement: Either the original use of the property in the Zone must commence with the QOF, or the QOF must substantially improve the property • “Substantially All” Use Test: Substantially all of the use of the property must be within the Qualified Opportunity Zone. The proposed IRS regs have defined “substantially all” as 70% Source and for more information: https://www.irs.gov/newsroom/opportunity-zones-frequently-asked-questions

  9. A key take away – while QOFs must invest substantially in OZ’s, a material amount of their assets may be invested elsewhere • 70% of QOZ Business or Business Property must be within the Zone 90% required to be in Qualified Opportunity Zone Property • 30% of QOZ Business or Business Property may fall outside the Zone • Qualified • Opportunity • Fund 10% may be held in any other assets (cash or investments) Directly and indirectly, ~37% of QOF assets are eligible to be held or invested outside a Zone

  10. Contents j • What are Opportunity Zones . . . and why you should care k • How SAM is seizing this opportunity l • Illustrative projects

  11. Charlotte and Charleston share several distinctive strengths as focal points for real estate investment Leading destinations for business • A total of 20 Fortune 1000 headquarters in the two cities, alongside dozens of other Nasdaq, NYSE, and Inc 500 firms • A diverse range of new economy and old economy industries – not overexposed to one company (Seattle) or one industry (Houston) • Attractive business climates – e.g., North Carolina and South Carolina rank #1 and #15 in Fortune’s “Best States for Business” rankings Increasing magnets for people • Both metro areas are beneficiaries of a demographic shift that is increasingly seeing young people move to the Southeast • From 2017 to 2018, Charlotte grew at 3x the rate of the overall US population; Charleston grew at 2.7x the rate • Both exhibit strong economic health as reflected in metrics such as job creation and wage growth Highly favorable housing market dynamics • The ideal geography for real estate investment would feature home prices and rents appreciating at rates above the national average . . . • But also home prices and rents starting from a low base, i.e., still affordable – leaving ample runway for growth • Charlotte and Charleston meet these criteria better than most other cities in America Sources: TaxFoundation.org (business tax climate ratings), http://www.charlottestories.com/charlotte-named-2017s-2nd-fastest-growing-large-city-america/, https://www.census.gov/newsroom/press-releases/2019/subcounty-population-estimates.html; https://www.forbes.com/best-states-for-business/list/#tab:overall

  12. Both metros are home to leading American corporations across a diverse range of industries . . . Sources: Charlotte Chamber of Commerce, Charleston Chamber of Commerce

  13. Charlotte’s population growth, job growth, and wage growth are among the highest in America • Charlotte Metro Area Population Growth, 2008 - 2018 • Charlotte – Key Statistics • Total 10 year population growth +53% • Average annual job growth post 2009 +2.9% • Annual wage growth 2016 – 2017 +5.55% • #2 fastest growing city among America’s 25 largest cities • #1 fastest growing city among Millennials, +30% from 2005 - 2015 Sources: U.S. Census Bureau, U.S. Bureau of Labor Statistics (BLS), Charlotte Observer, Apartment List Ranking for large cities based on cities with at least 500,000 residents and population growth from 2005 – 2015 https://www.statista.com/statistics/815294/charlotte-metro-area-population/

  14. The Charleston metro area has experienced a similar economic and population boom • Charleston – Key Stats • Charleston Metro Area Population Growth, 2008 - 2018 • Total 10 year population growth +25% • Average annual job growth post 2009 +3.0% • Annual wage growth 2015 – 2016 +4.4% • #4 fastest growing city nationwide • #1 city for small business growth • #13 for presence of fast growth firms in the Inc 5000 Sources: www.crda.org (population and employment data), https://ceoworld.biz/2018/08/09/here-are-the-top-25-fastest-growing-cities-in-the-united-states-2018/ (growth), Post & Courier (wage growth), https://www.charlestondigitalcorridor.com/about/charleston/ (small business growth and presence of Inc 5000 firms)

  15. Home price appreciation in Charlotte and Charleston are accelerating above the national average . . . but from lower, more affordable bases • Annual Change in Home Prices, 2006 - 2018 • Home prices have recovered to slightly above their pre-crises levels nationally as well as in both metros • Since ~2013, home prices in Charlotte and Charleston have begun to appreciate at a rate nicely above the national average, as the cities’ natural strengths have affected supply/demand favorably • We believe both metros can continue to see secular home price appreciation above 5% p.a. over the next decade Source: Federal Reserve Bank of St. Louis FRED data, www.stlouisfed.org; Domicilium analysis

  16. Despite recent gains, home prices in Charlotte and Charleston are still among the most affordable nationally among major markets Seattle $739,600 Chicago $228,500 Manhattan, NYC $1,293,000 San Francisco $1,374,400 Los Angeles $679,200 Washington, DC $571,700 Charlotte $216,500 Phoenix $235,200 Charleston $249,500 Dallas $233,200 Miami $333,600 Source: Zillow single-family home prices, October 2018. Prices reflect reported medians. Charleston data includes North Charleston.

  17. Median rents (all housing types) in these metros likewise compare favorably to other cities Seattle $2,600 Chicago $1,700 New York City $3,400 San Francisco $4,550 Los Angeles $3,150 Washington, DC $2,680 Charlotte $1,445 Phoenix $1,475 Charleston $1,650 Dallas $1,695 Miami $2,500 Source: Zillow, October 2018. Prices reflect reported medians. Charleston data includes North Charleston.

  18. Not surprisingly, the creation of Opportunity Zones has already resulted in a “feeding frenzy” of price escalation in certain OZ’s around the country “Sales of development sites in opportunity zones nationwide have spiked 80% in the first three quarters of 2018, compared with the same period last year, according to data firm Real Capital Analytics. Meanwhile, owners have marked up asking prices for land or properties in some zones by more than 50%, market participants say. This has been especially true in parts of Oakland, San Diego, Phoenix, Atlanta, Portland, Ore., and other growing cities where real-estate speculation had been stirring even before the program started . . . [I]nvestors clearly view some zones as more primed for growth than others. In the Bronx, for example, investors purchased $225.7 million worth of development sites in zones in the first nine months of 2018, up from $24 million during the same period in 2017, according to Real Capital. The increased demand is pushing up asking prices. In Portland, owners of development sites in zones are asking as much as 50% more than two years ago, brokers say.” • WSJ, October 23, 2018 https://www.wsj.com/articles/developers-look-to-hit-tax-break-jackpot-in-opportunity-zones-1540296000

  19. We have not observed similar significant price inflation (yet) in Charlotte and Charleston . . . • Both Charlotte and Charleston received fairly generous OZ designations – well over 25% of the footprint of both metros has been OZ designated • We know the OZ designated areas in both cities well and have not yet observed a material escalation in transaction volume or prices • Domicilium’s independent administrator – NES Financial – is also one of the largest administrator for Qualified Opportunity Funds (QOFs) in the country • Of the > 40 QOFs for which NES serves as independent administrator – including two QOFs that have raised over $1 billion - none are focused primarily on Charlotte and/or Charleston • We believe there is a limited window of time to seize on OZ opportunities in both metros before they begin to experience inflation similar to what has already unfolded in areas such as the Bronx, Chicago, Oakland and Portland

  20. Domicilium’s leadership – Micah Simon, CIO and Managing Member • Micah Simon’s experience in real estate spans over two decades, dating to his years as an undergraduate at UNC – Charlotte when he earned his general contractor license and began buying, rehabilitating, and selling properties to pay for college • Since that time, Micah has built deep domain knowledge in every relevant aspect of the real estate value chain, with a particular focus on the Charlotte and Charleston metro areas: • As investor, he has personally owned, developed, and managed over ~1,000 properties in the Charlotte area over a two decade period • As a general contractor, Micah’s company has built over ~250 homes and remodeled over ~550 others, working as a preferred partner for marquee institutional firms such as Invitation Homes, Colony Homes, and American Homes 4 Rent • His firm has also done extensive construction work on behalf of national homebuilders such as Pulte, DR Horton, Ryan Homes, KB Homes, Keystone Builders, and Mercedes Homes – framing and roofing ~600 single family homes per year and ~1,300 townhomes per year during peak periods • As a developer, Micah has developed ~700 – 800 acres in the Charlotte area spanning several projects. His experience as a developer includes selling lots for cash, selling with owner financing, assembling parcels and re-zoning to enhance value, as well as traditional development • Across all of these activities, Micah has developed deep expertise working with local government and relevant stakeholders to obtain entitlements, re-zoning, and permits so as to unlock value • Micah’s two plus decades in the Charlotte real estate community have also led him to build a proprietary network of bankers, builders, accountants, attorneys, engineers, insurers, tradesmen, vendors, and property management professionals touching every aspect of real estate activity

  21. Key capabilities • Developing, managing, and harvesting an OZ property portfolio requires domain knowledge, experience, and execution capabilities in several interrelated facets of the business • Domicilium benefits from Micah Simon’s two plus decades of experience in each of these areas and a deep network of contacts across the real estate value chain in both Charlotte & Charleston • We expect this network to be especially powerful in sourcing “off market” opportunities to acquire portfolios, land, and properties with strategic value • Granular knowledge of how our geographies are likely to develop (e.g., zoning, gentrification, and development plans of major strategic property investors) may also impart a competitive advantage in identifying where and what to acquire • Domicilium will “in source” several key functions, including acquisition and some property management and construction responsibilities • Selective aspects of finance, property management, and construction will be outsourced when it is cost effective for the fund to do so • Where we believe outsourcing is more cost effective, Domicilium benefits from longstanding relationships with key vendors – we will not need to “blind date” • Human capital • Hire • Train • Retain staff • Acquisition • Sourcing • Due diligence • Execution • Property Management • Leasing • Rent collection • Repair and Maintenance • Construction • Lot development • Purchasing • Building • Finance • Accounting • Tax • Financing

  22. Contents j • What are Opportunity Zones . . . and why you should care k • How SAM is seizing this opportunity l • Illustrative projects

  23. ILLUSTRATIVE Project #1: Charlotte – Tryon Hills “bridge” to NODA • Tryan Hills is a gentrifying neighborhood about 1 - 1.5 miles from downtown Charlotte Proposed OZ Project Site • Just North of Tryan Hills is the North Tryon Mall, a ~26 acre mall made of up ~15 parcels that has succumbed to the “death of retail” Downtown Charlotte • Based on preliminary conversations with parcel owners, we would estimate the entire mall footprint could be bought for ~$20 million Proposed OZ Project Site • The mall sits directly adjacent, less than a quarter mile, from NODA, a popular, “artsy” neighborhood that has already seen dramatic escalation in property values “NODA” – “North Davidson • The mall sits squarely within a designated OZ. We believe it presents a compelling risk/reward site for mixed use re-development The above case study is being provided for illustrative purposes and should not necessarily be considered indicative of the projects that Domicilium will invest in. Domicilium’s investment process and analysis set forth below is for illustrative purposes.  Domicilium may modify its approach and parameters at any time an in any manner in which it believes is consistent with Domicilium’s overall investment objective, without notice to investors. 

  24. ILLUSTRATIVE Project #2: Charleston metro Volvo plant infrastructure buildout • Volvo is building a $1.2 billion, 1600 acre manufacturing campus, its first plant in North America, in the Charleston metro • The facility aims to directly employ 4,000 FTEs, create an additional 4,000 local jobs, and produce ~100k vehicles p.a. • The first Volvo S60 sedans rolled off the assembly line at the plant on September 28, 2018 and production is currently scaling • The manufacturing campus itself and the area surrounding it sit squarely within a designated Federal Opportunity Zone • The area surrounding the plant is entirely undeveloped. We believe this presents an exceptional opportunity to develop diverse infrastructure in support of the facility Charleston Volvo Campus North Charleston The above case study is being provided for illustrative purposes and should not necessarily be considered indicative of the projects that Domicilium will invest in. Domicilium’s investment process and analysis set forth below is for illustrative purposes.  Domicilium may modify its approach and parameters at any time an in any manner in which it believes is consistent with Domicilium’s overall investment objective, without notice to investors.  References: https://www.statista.com/statistics/815294/charlotte-metro-area-population/

  25. SAM - Domicilium OZ Fund I: Key Investment Terms NOT FOR FURTHER DISTRIBUTION The Key Investment Terms described on this page indicate the anticipated portfolio construction of the Domicillium Opportunity Zone Fund I; however, these terms are not fixed and may be modified from time to time by Domicilium in response to changing market conditions in any manner it believes is consistent with the Domicilium’s overall investment objective. In particular, target returns, portfolio composition, expected IRR and other projections herein are based on the prior experience of Domicilium, and other factors it deemed relevant, including current and expected market conditions. [References herein to target returns means projected investor returns net of management fee and other expenses, but before incentive allocation.]

  26. Disclosure Stansberry Asset Management, LLC is providing this information for informational purposes only and any investment decision should be made based solely on the contents of the offering documents. Certain principals of Stansberry Asset Management, LLC have an ownership interest in the SAM-Domicilium Qualified Opportunity Zone Fund I and may benefit economically from new investments in the Company. The target returns stated in this presentation are the net returns that the Company currently anticipates based on the management team’s experience with factoring. Expenses and interest rates have all been estimated for purposes of this presentation. The actual net returns earned by an investor may be materially lower. The terms described herein, including the Company’s operating parameters, are subject to change. Stansberry Research LLC (“Stansberry Research”) is a subscription-based publisher of financial information. Stansberry Research is not regulated by the SEC because it is a publisher. Stansberry Research and Stansberry Asset Management (“SAM”) are separately operated and are overseen by different boards. SAM’s management team is responsible for the investment decisions of SAM. The members of SAM’s management team are not officers or editors of Stansberry Research and have no financial interest in Stansberry Research. Porter Stansberry and the other writers at Stansberry Research are not personally involved in the day-to-day management of SAM or its investment advisory services. Although SAM will utilize investment research published by Stansberry Research, SAM has no special or early access to such research. They receive information from Stansberry Research just like any other subscriber does- after the issues are published. A solicitation arrangement exists under which Stansberry Research will be compensated by SAM if you enter into an investment advisory relationship with SAM. Additional information about this arrangement and Stansberry Research will be furnished if you request additional materials about SAM. The success of the client accounts depends on the ability and experience of SAM and there can be no assurance that SAM will generate any gains or profits for client accounts. No investment strategy or risk management technique can guarantee returns or eliminate risk in any market environment. Future returns are not guaranteed and a loss of principal may occur. The presentation reflects the current opinions of SAM and the SAM Domicilium Qualified Opportunity Zone Fund I. The opinions which are subject to change without notice, and SAM does not undertake to correct or update any factual information.

  27. Disclosure THIS DOCUMENT, WHICH IS BEING PROVIDED ON A CONFIDENTIAL BASIS, SHALL NOT CONSTITUTE AN OFFER TO SELL OR THE SOLICITATION OF ANY OFFER TO BUY WHICH MAY ONLY BE MADE AT THE TIME A QUALIFIED OFFEREE RECEIVES A CONFIDENTIAL PRIVATE OFFERING MEMORANDUM (“CPOM”), WHICH CONTAINS IMPORTANT INFORMATION (INCLUDING INVESTMENT OBJECTIVE, POLICIES, RISK FACTORS, FEES, TAX IMPLICATIONS AND RELEVANT QUALIFICATIONS), AND ONLY IN THOSE JURISDICTIONS WHERE PERMITTED BY LAW. IN THE CASE OF ANY INCONSISTENCY BETWEEN THE DESCRIPTIONS OR TERMS IN THIS DOCUMENT AND THE CPOM, THE CPOM SHALL CONTROL. THESE SECURITIES SHALL NOT BE OFFERED OR SOLD IN ANY JURISDICTION IN WHICH SUCH OFFER, SOLICITATION OR SALE WOULD BE UNLAWFUL UNTIL THE REQUIREMENTS OF THE LAWS OF SUCH JURISDICTION HAVE BEEN SATISFIED. THIS DOCUMENT IS NOT INTENDED FOR PUBLIC USE OR DISTRIBUTION. WHILE ALL THE INFORMATION PREPARED IN THIS DOCUMENT IS BELIEVED TO BE ACCURATE, STANSBERRY ASSET MANAGEMENT LLC, MAKES NO EXPRESS WARRANTY AS TO THE COMPLETENESS OR ACCURACY, NOR CAN IT ACCEPT RESPONSIBILITY FOR ERRORS, APPEARING IN THE DOCUMENT.  AN INVESTMENT IN THE SAM DOMICILIUM OPPORTUNITY ZONE FUND I (THE “FUND”) IS SPECULATIVE AND INVOLVES A HIGH DEGREE OF RISK. OPPORTUNITIES FOR WITHDRAWAL AND TRANSFERABILITY OF INTERESTS ARE RESTRICTED, SO INVESTORS MAY NOT HAVE ACCESS TO CAPITAL WHEN IT IS NEEDED. THERE IS NO SECONDARY MARKET FOR THE INTERESTS AND NONE IS EXPECTED TO DEVELOP. THE PORTFOLIO IS PRIMARILY CONCENTRATED IN REAL ESTATE IN THE SOUTHEASTERN UNITED STATES AND THIS LACK OF DIVERSIFICATION MAY RESULT IN HIGHER RISK. LEVERAGE MAY BE EMPLOYED IN THE PORTFOLIO, WHICH CAN MAKE INVESTMENT PERFORMANCE VOLATILE. AN INVESTOR SHOULD NOT MAKE AN INVESTMENT, UNLESS IT IS PREPARED TO LOSE ALL OR A SUBSTANTIAL PORTION OF ITS INVESTMENT. THE FEES AND EXPENSES CHARGED IN CONNECTION WITH THIS INVESTMENT MAY BE HIGHER THAN THE FEES AND EXPENSES OF OTHER INVESTMENT ALTERNATIVES AND MAY OFFSET PROFITS. THE FUND PAYS STANSBERRY ASSET MANAGEMENT, LLC A PORTION OF THE MANAGEMENT FEE CHARGED BY THE FUND. CERTAIN MEMBERS OF STANSBERRY ASSET MANAGEMENT, LLC ALSO OWN A PORTION OF THE MANAGEMENT COMPANY AND GENERAL PARTNER THAT IS SPONSORING THE FUND, AND AS SUCH WILL INDIRECTLY SHARE IN THE MANAGEMENT FEES AND CARRIED INTEREST PAID BY THE FUND. WHILE STANSBERRY ASSET MANAGEMENT, LLC BELIEVES THAT THE FUND IS AN APPROPRIATE INVESTMENT FOR MANY OF ITS CLIENTS, STANSBERRY ASSET MANAGEMENT, LLC AND ITS PRINCIPALS FACE AN ONGOING CONFLICT OF INTEREST IN RECOMMENDING THAT CLIENTS INVEST IN THE FUND. WHILE STANSBERRY ASSET MANAGEMENT, LLC SEEKS TO MANAGE AND MITIGATE THESE CONFLICTS OF INTEREST ON AN ONGOING BASIS, THERE CAN BE NO ASSURANCES THAT THEY WILL BE SUCCESSFUL. THE VIEWS EXPRESSED HEREIN ARE THE VIEWS OF SAM-DOMILICIUM AND STANSBERRY ASSET MANAGEMENT LLC AND ARE SUBJECT TO CHANGE. MOREOVER, THE PAST PERFORMANCE OF THE INVESTMENT TEAM SHOULD NOT BE CONSTRUED AS AN INDICATOR OF FUTURE PERFORMANCE. ANY PROJECTIONS, MARKET OUTLOOKS OR ESTIMATES IN THIS DOCUMENT ARE FORWARD‑LOOKING STATEMENTS AND ARE BASED UPON CERTAIN ASSUMPTIONS. OTHER EVENTS WHICH WERE NOT TAKEN INTO ACCOUNT MAY OCCUR AND MAY SIGNIFICANTLY AFFECT THE RETURNS OR PERFORMANCE OF INVESTMENTS. ANY PROJECTIONS, OUTLOOKS OR ASSUMPTIONS SHOULD NOT BE CONSTRUED TO BE INDICATIVE OF THE ACTUAL EVENTS WHICH WILL OCCUR.

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