Pacific Capital Advisors,

Inc. (Vanguard)

Fund Investment Objectives

Summary: The Vanguard Program is a systematic absolute return strategy that trades the S&P500 e-mini and U.S. interest rate futures contracts. At this time, the program has an estimated capacity of over $100 million. Investment Strategy: PCA's Vanguard Program trades stock index and interest rate futures. The program is 100% systematic. Both mean reversion and momentum trading methods are used to exploit various market conditions. Stop-loss levels and diversification across sectors help control risk. Average holding period is 5 days. The methods used in the Vanguard Program are based upon a variety of techniques. Price patterns on daily, weekly and monthly time-frames provide setups for momentum or mean reversion trades. The core principles of these techniques have shown effectiveness across many markets over many years of historical testing. Not all methods are applied to all markets. Some markets exhibit characteristics best suited for breakout or momentum trading, while others are best traded using mean-reversion methods. The most appropriate method or methods are applied to suitable markets. Markets traded are selected based upon liquidity, volatility, potential profitability and potential diversification. *** Please note that this program traded stock indices intraday only from inception through June 2013. From July 2013 forward the program has been traded as described above *** Risk Management: Stop loss orders are used for open trades. Diversification across markets affords some potential risk reduction.