OVERVIEW OF CLARK CAPITAL
Clark Capital is a registered independent investment advisor that has been managing investor assets since 1986. We are a closely
held employee-owned business located in Philadelphia, Pennsylvania, with all significant owners currently employed by the firm
in key management, operations, portfolio management and sales capacities. The controlling ownership of the firm resides with
Harry Clark, our Executive Chairman.
Our advisory services are offered through a variety of channels, including: (1) wrap fee and dual contract managed account
programs sponsored by third parties (collectively, “Third-Party Wrap Fee Programs”); (2) programs where we provide investment
recommendations in the form of a model portfolio to third parties (“Model Delivery” or “Model Delivery Programs”) (3)
registered investment companies (the “Navigator Mutual Funds”); and (4) private clients through a turnkey asset management
programs offered by Clark Capital (“Clark Capital Wrap Fee Programs”). As of 12/31/2023, the firm managed $33,395,035,104
in total assets, $25,930,824,625 of which were managed on a discretionary basis, and $7,464,210,479 of which were managed
on a Model Delivery basis.
The information in this Wrap Fee Brochure is primarily related to the advisory services we provide through the Clark Capital
Wrap Fee Programs. As of 12/31/2023, the total assets in Clark Capital Wrap Fee Programs was $101,258,891. For more
information on other services we offer, please read Clark Capital’s Form ADV Part 2A and the prospectuses and relevant offering
materials for the Navigator Mutual Funds.
OUR PHILOSOPHY
Clark Capital’s investment philosophy is driven by a single-minded focus: to add value for our clients. This focus requires us to
produce institutional investment solutions that aim to consistently generate competitive risk-adjusted returns over full market
cycles. It compels us to maintain a long-term perspective and provide innovative investment management solutions that add
value for our clients. It also requires us to place an emphasis on risk management, because understanding and managing risk is
critical to our clients’ investment success. We firmly believe that successful investment management rests not on the ability to
excel through any one of these elements, but through the combined strength of all of them.
ADVISORY SERVICES
With over three decades experience providing wealth management solutions to investors, Clark Capital has navigated our clients'
wealth through a variety of investment environments. We offer investment solutions to individuals, businesses, institutions,
investment companies and financial services firms and their clients. Portfolios may be customized to effectively meet clients'
risk and return objectives.
Clark Capital generally has discretionary authority to manage accounts on behalf of our clients, which includes determining the
securities to be bought or sold for a client’s account and the amount of those securities, the broker or dealer to be used for
purchase or sale of securities for a client’s account, and the commission rates to be paid to a broker or dealer for a client’s
securities transactions. Also, you should note that we have full discretion to determine when your assets are invested, both when
we begin to manage your account and upon receipt of additional contributions to your account.
MEETING THE NEEDS OF INDIVIDUAL INVESTORS
Prior to engaging us as an investment advisor, we will obtain information about your financial situation, investment objectives
and risk comfort zone and suggest a potential investment in our wrap program. On the basis of the information that we receive
from you, our portfolio team will review your situation and determine if the suggested program is suitable. We will then prepare
an investment proposal for your review. If you accept the proposal, an Investment Advisory Agreement is completed and agreed
to by you and Clark Capital. As such, our services will be based upon your individual needs, stated objectives and guidelines as
set forth in these written agreements. We make all investment decisions on your account without your prior approval of each
specific transaction; however, all such decisions are made within the boundaries of your stated objectives and guidelines and the
terms of your agreement with us. As a client in one of these wrap fee programs, you generally have the ability to impose
reasonable restrictions on the management of your account. In such instances and when feasible, Clark Capital will refrain from
buying securities or types of securities in accordance with your restrictions. Annually, Clark Capital will contact you to evaluate
the continuing suitability of the program.
CLARK CAPITAL’S WRAP FEE PROGRAMS
Clark Capital sponsors two Wrap Fee Programs: Navigator Unified Solutions and Navigator Personalized Unified Managed
Account (“PUMA”). In Clark Capital’s Wrap Fee Programs, our investment advisory services, the cost of transactions and
custodial fees are all “wrapped” into a single fee based on the value of your portfolio. We help you select one of the investment
strategies listed below based upon your individual needs, stated objectives and guidelines as set forth in written agreements
between you and Clark Capital. The investment strategy descriptions provided below are general in nature and may be
customized and/or include reasonable investment restrictions imposed by our clients. In certain instances, and when feasible,
Clark Capital will refrain from buying certain securities or types of securities upon instruction from the client(s). We reserve the
right to limit the availability of any particular investment strategy at any given time based on various factors including asset class
capacity, pre-existing relationships, minimum account sizes, fees and distribution channels. Certain investment strategies may
be available only in certain channels. Clark Capital manages Wrap Fee Program accounts according to the general investment
strategies described below. Other customized strategies may be offered from time to time. Our services include, without
limitation, management of equity, fixed income, balanced and other specialty investment portfolios.
NAVIGATOR UNIFIED SOLUTIONS
Navigator Unified Solutions (or “Unified Solutions”) is a legacy program that is no longer offered to new clients. Navigator
Unified Solutions is a unified managed account (“UMA”) that is a core and explore asset allocation program that emphasizes
diversification. Clark Capital combines multiple investment products, coordinates portfolio administration and allocates the
assets of the portfolio at its sole discretion. From time to time, Clark Capital will reallocate portfolios. Portfolio allocations are
selected from the following asset classes: U.S. equities, international equities, fixed income, and alternative investments.
Portfolios are constructed drawing upon the following: mutual funds; exchange traded funds; fixed income securities; and
alternative investments.
Core and explore asset allocation is employed in the segments of the portfolio holding U.S. equities, international equities, and
fixed income. The core segment is focused upon market diversification across market capitalizations and styles and explore is
focused upon economic sectors and world markets that are believed to have the potential of producing excess performance.
There are five risk-based portfolios to choose from in Unified Solutions:
• Level I: Level I portfolios seek to provide preservation of capital and inflation protection with current income. Capital
appreciation is a secondary goal. These portfolios are designed for investors who have a low risk comfort zone and are
willing to accept commensurate returns in exchange for asset preservation. Portfolios with a risk level of Level I are
constructed of 20 to 30% U.S. equity, 5 to 15% international equity, 40 to 60% fixed income, 10 to 20% alternative
assets, 2 to 12% global tactical (formerly known as global macro), and 0 to 15% cash.
• Level II: Level II portfolios seek to provide limited capital appreciation and modest current income with a secondary
goal of capital preservation. These portfolios are for the investor who has a limited risk comfort zone and is willing to
accept minimal volatility in exchange for modest wealth enhancement. Portfolios with a risk level of Level II are
constructed of 20 to 45% U.S. equity, 10 to 20% international equity, 15 to 35% fixed income, 10 to 25% alternative
assets, 5 to 15% global tactical (formerly known as global macro), and 0 to 15% cash.
• Level III: Level III portfolios seek to provide moderate capital appreciation and limited current income with a secondary
goal of capital preservation. These portfolios are designed for investors who have a moderate risk comfort zone and are
willing to accept limited volatility in exchange for moderate wealth enhancement. Portfolios with a risk level of Level
III are constructed of 30 to 45% U.S. equity, 15 to 25% international equity, 5 to 20% fixed income, 10 to 25%
alternative assets, 8 to 18% global tactical (formerly known as global macro), and 0 to 15% cash.
• Level IV: Level IV portfolios seek capital appreciation. These portfolios are designed for investors who have a high risk
comfort zone and are willing to accept volatility in exchange for potential wealth enhancement. Current income is not
a consideration. Portfolios with a risk level of Level IV are constructed of 35 to 55% U.S. equity, 20 to 30% international
equity, 0 to 10% fixed income, 5 to 30% alternative assets, 10 to 20% global tactical (formerly known as global macro),
and 0 to 15% cash.
• Level V: Level V portfolios seek to maximize capital appreciation. These portfolios are designed for investors who have
a high risk comfort zone and are willing to accept more volatility in exchange for greater potential wealth enhancement.
Current income is not a consideration. Portfolios with a risk level of Level V are constructed of 40 to 60% U.S. equity,
20 to 30% international equity, 0 to 10% fixed income, 5 to 30% alternative assets, 10 to 20% global tactical (formerly
known as global macro), and 0 to 15% cash.
The minimum account size is $100,000. Portfolios are constructed to each risk level using the account components described
below. Components selected for each portfolio vary with account size range. Account size ranges for each risk level are
described under “Fees and Compensation.”
NAVIGATOR PERSONALIZED UNIFIED MANAGED ACCOUNT (“PUMA”)
With a Personalized Unified Managed Account (“PUMA”) the client may choose to incorporate investment strategies featuring
one or more of the account components listed below which utilize different investment styles, strategies, and investment vehicles
in one managed account. Portfolio allocations are selected by the client from the following asset classes: U.S. equities,
international equities, fixed income, and alternative investments. Portfolios draw upon the following: mutual funds; exchange
traded funds; fixed income securities; and alternative investments including real estate, commodities, precious metals, currencies
and absolute return/hedge strategies. The minimums for components of a PUMA are given below. The account must have a
minimum size of $50,000 and must incorporate two or more components prior to adding an Alternative component. Portfolios
are constructed using the account components described below.
CORE U.S. EQUITY
Navigator All Cap Core U.S. Equity Component Minimum $50,000
The Navigator All Cap Core U.S. Equity portfolio is primarily invested in stocks of companies with market capitalizations
generally falling between $300 million and $400 billion and that are constituents of the Russell 3000 Broad Market Index. Our
investment process is both quantitative and qualitative, incorporating proprietary models and analytical techniques that search
for companies that possess three characteristics: superior quality, attractive value and improving business prospects. By
purchasing the undervalued shares of companies with a durable competitive advantage whose businesses have accelerating
momentum, we tend to benefit over time as value increases and as the spread between price and value narrows. Our risk controls
are sensitive to company and sector diversification to reduce both overall portfolio volatility and tracking error to the benchmark.
The goal of the portfolio is to deliver consistent excess returns over a full market cycle at/or below benchmark volatility.
Navigator High Dividend Equity Component Minimum $50,000
Navigator High Dividend Equity is invested in high-quality domestic and international equities, REITs and preferred stocks. The
goal of the strategy is to provide above average dividend income with capital appreciation. The focus is on reasonably priced,
multi-capitalized stocks with strong valuation characteristics. Only securities with strong and absolute relative values are
considered for use in the portfolio and is diversified across several broad economic sectors. Fundamental and quantitative analysis
is used in determining the stocks to be included in the portfolio such as: revenue growth, price/cash flow, price/book, P/E, ROE
(return on equity), price/sales, dividend yield, PEG ratios and earnings momentum. Generally, 35 to 55 securities are held in the
portfolio. Preferred stocks and REITs are considered for the portfolio. The sell discipline considers dividend reductions,
weakening earnings trends and declining margins over two to three consecutive quarters. Relative performance to market peers
is also a factor. The strategy seeks to provide capital appreciation with current income on a consistent basis by applying a fundamental
investment approach that is focused on securities with above average dividend yield.
Navigator Small Cap Core U.S. Equity Component Minimum $50,000
The Navigator Small Cap Core U.S. Equity portfolio primarily invests in stocks of companies with market capitalizations
generally falling between $300 million and $3 billion and that are constituents of the Russell 2000 Small Cap Index. Our
investment process is both quantitative and qualitative, incorporating proprietary models and analytical techniques that search
for companies that we believe possess three characteristics: superior quality, attractive value and improving business prospects.
By purchasing the undervalued shares of companies with a Durable Competitive Advantage whose businesses have accelerating
momentum, we tend to benefit over time as value increases and as the spread between price and value narrows. Our risk controls
are sensitive to company and sector diversification to reduce both overall portfolio volatility and tracking error to the benchmark.
The goal of the portfolio is to deliver consistent excess returns over a full market cycle at/or below benchmark volatility. The
performance prior to 4/1/2003 were achieved by Anthony Soslow while at his prior firm, using a substantially similar investment
style. Anthony Soslow joined Clark Capital Management Group on 3/1/2013.
Navigator SMID Cap Core U.S. Equity Component Minimum $50,000
The Navigator SMID Cap Core U.S. Equity portfolio primarily invests in stocks of companies with market capitalizations
generally falling between $300 million and $5 billion. Our investment process is both quantitative and qualitative, incorporating
proprietary models and analytical techniques that search for companies that possess three characteristics: superior quality,
attractive value and improving business prospects. By purchasing the undervalued shares of companies with a Durable
Competitive Advantage whose businesses have accelerating momentum, we tend to benefit over time as value increases and as
the spread between price and value narrows. Our risk controls are sensitive to company and sector diversification to reduce both
overall portfolio volatility and tracking error to the benchmark. The goal of the portfolio is to deliver consistent excess returns
over a full market cycle at/or below benchmark volatility.
Navigator U.S. Equity Strategic Beta Component Minimum $25,000
Navigator U.S. Equity Strategic Beta is designed to provide broad U.S. equity market diversification by utilizing domestic equity
exchange traded funds. This composite is highly tax efficient, passively managed and serves as the anchor or core of a total
unified composite. The core composite will be tax managed to minimize capital gains transactions. The investment approach
seeks wide diversity through inclusion of all capitalizations and styles of the domestic equity market and is constructed so that
the broad U.S. equity market will be mirrored. These ETFs are passively managed with the objective of the same performance
as the indexes they are tracking. The composite will be over-weighted in large cap indexes that have significant dividend yield.
The strategy seeks to provide capital appreciation over a market cycle with a focus on dividends in a broadly diversified domestic
equity composite
CORE INTERNATIONAL EQUITY
Navigator International Equity/ADR Component Minimum $50,000
The Navigator International Equity/ADR portfolio primarily invests in American depository receipts (ADRs) of companies with
market capitalizations generally falling between $300 million and $250 billion and are constituents of the MSCI All Country ex
US Index. Our investment process is both quantitative and qualitative, incorporating proprietary models and analytical techniques
that search for companies that we believe possess three characteristics: superior quality, attractive value and improving business
prospects. By purchasing the undervalued ADRs of companies with a durable competitive advantage whose businesses have
accelerating momentum, we tend to benefit over time as the spread between price and value narrows and value increases. Our
risk controls are sensitive to country and sector diversification to reduce both overall portfolio volatility and tracking error to the
benchmark. The goal of the portfolio is to deliver consistent excess returns over a full market cycle at/or below benchmark
volatility. The performance results prior to 4/1/2013 were achieved by Anthony Soslow while at his prior firm, using a
substantially similar investment style. Anthony Soslow joined Clark Capital Management Group on 3/31/2013.
Navigator International Equity Core Component Minimum $25,000
Navigator International Equity Core seeks to provide capital appreciation over a market cycle. The portfolio invests in broad
based international equity exchange traded products and actively managed mutual funds by applying a fundamental investment
approach. The diversified portfolio has the objective of providing broad-based international equity exposure. While limited
strategic emphasis may be placed on emerging markets, broad diversification is always maintained. Portfolio construction
employs a "top down” approach seeking wide diversity reflective of international markets. Construction of the portfolio begins
with a rigorous due diligence process to select the mutual funds or exchange traded products. Due diligence focuses on long-
term performance in up and down markets, style consistency, performance attribution and manager correlation. The process
includes a detailed review by the Clark Capital Investment Committee for attributes such as manager tenure, investment
processes, systems and trading capabilities, legal and compliance resources, and personnel and organizational structure.
Navigator International Equity Strategic Beta Component Minimum $25,000
The Navigator International Equity Strategic Beta seeks to provide capital appreciation over a market cycle. The portfolio invests
in broad based international equity exchange traded funds by applying a fundamental investment approach. The diversified
portfolio has the objective of providing broad-based international equity exposure. While limited strategic emphasis may be
placed on emerging markets, broad diversification is always maintained. Portfolio construction employs a passive "top down”
approach seeking wide diversity reflective of international markets with limited turnover. Construction of the portfolio begins
with a rigorous due diligence process to select the exchange traded funds.
CORE FIXED INCOME
Navigator Tax-Free Fixed Income Component Minimum $150,000
Navigator Tax-Free Fixed Income portfolio is comprised of those accounts invested in high credit quality (average quality is
investment grade or better) individual tax-free municipal securities. The portfolio is constructed to control risk through
maintaining duration in the portfolios (a measure of interest rate sensitivity) of between four and seven years. The strategy seeks
to provide current income on a consistent basis by applying a fundamental investment approach. Active management in the
portfolios seeks to provide returns to the stated benchmark through state, sector and security selection. Portfolio turnover will
vary based on market opportunities such as tax loss harvesting and yield curve shifts. State-specific variations on the tax-free
fixed income strategy are also offered. These strategies provide at least 80% targeted exposure to state-specific municipal bonds
and seek to deliver total return with a secondary goal of income. Municipal bond issues from the following states are offered as
part of these state-specific strategies: California, New Jersey, New York and Pennsylvania.
Navigator Tax-Free Fixed Income Core Component Minimum $25,000
Navigator Tax-Free Fixed Income Core is designed to maximize total return by investing actively across the full maturity and
investment grade spectrum of municipal fixed income securities. The strategy seeks to add value through a rigorous investment
discipline that identifies market inefficiencies in the valuation of risk and reward, combined with an effort to capitalize upon
shifting market themes, yield curve inefficiencies, and undervalued maturities. The portfolio is constructed in an effort to control
risk by maintaining composite duration (a measure of interest rate sensitivity) in adherence to the benchmark range of four to
seven years. Active management is supported by in-depth, internally generated research looking to pursue superior performance
results with greater consistency and lower volatility of returns. The strategy seeks to provide a high level of tax-free total return
and current income by investing in municipal bond mutual funds and exchange traded funds.
Navigator Taxable Fixed Income Component Minimum $150,000
Navigator Taxable Fixed Income invests in corporate bonds, government bonds, mortgage securities and taxable municipal
bonds. The portfolio is managed to opportunistically take advantage of changing expectations regarding the shape of the yield
curve, credit spreads, and sector valuation. The average duration of the composite is maintained at the intermediate range of four
to eight years in order to limit interest rate risk, but bonds of longer maturities of 20 – 25 years may be purchased in order to
build a higher yielding composite. The portfolio is generally fully invested and is appropriately diversified by sector, issuer, and
credit quality. The portfolio seeks to provide current income.
Navigator Taxable Fixed Income Core Component Minimum $25,000
Navigator Taxable Fixed Income Core is designed to maximize total return by investing actively across the full maturity and
investment grade spectrum of U.S. fixed income sectors and securities. The strategy seeks to identify market inefficiencies in the
valuation of risk and reward, combined with an approach to capitalize upon shifting market themes, yield curve inefficiencies
and undervalued maturities. Portfolios are constructed in an effort to control risk by maintaining portfolio duration (a measure
of interest rate sensitivity) in adherence to the composites intermediate benchmark range of four to eight years. Portfolios are
generally fully invested and are diversified among corporate, government and mortgage securities. Active management is
supported by in-depth, internally generated research to pursue performance results with greater consistency and lower volatility
of returns. The goal of the strategy is to provide a high level of total return by investing in high-quality corporate, government
bonds, treasury bonds, exchange traded products, and mortgage-backed securities.
Navigator Ultra Short Bond Fund
Clark Capital serves as advisor to the Navigator Ultra Short Bond Fund, which is registered as an open-end investment company.
The Fund invests primarily in various types of short duration, investment grade debt (or fixed income) securities. Additional
information about the Navigator Mutual Funds is available in the Funds’ prospectus and SAI, which are available on the Funds’
website (www.navigatorfund.com) or on the SEC’s EDGAR database.
TACTICAL U.S. EQUITY
Navigator U.S. Sector Opportunity Component Minimum $25,000
Navigator U.S. Sector Opportunity is primarily invested in U.S. sectors and industries through strategic rotation. The strategy
has an unconstrained asset allocation policy and is allocated to the sectors and industries that appear to have the potential for
producing exceptionally strong performance in the near future. A portfolio is constructed with a bias toward large cap equities
and weighted to pursue maximum returns. The portfolio is actively managed; security weightings are adjusted to take advantage
of emerging market opportunities as they arise to harvest gains as they mature. Portfolios are implemented using exchange traded
products which provide diversification, limit specific security risk, and provide tax efficiencies. The strategy seeks to provide
capital appreciation.
Navigator U.S. Style Opportunity Component Minimum $25,000
Navigator U.S. Style Opportunity invests in exchange traded funds through strategic rotation among U.S. equity styles (growth
& value), capitalizations (large, medium and small). The portfolio is then opportunistically overweighted in the market segments
expected to be the most profitable in the near term – large or small cap, growth or value, etc. – and underweighted in those
segments expected to be weaker. The strategy is passively managed using a strategic allocation of broad-based market indices,
rebalanced annually. The portfolio has an unconstrained asset allocation policy and seeks to maximize the returns through a
rigorous investment discipline that seeks to take advantage of the performance differential between segments of the equity market
under different market conditions. Style and capitalization rotation are employed in an effort to take advantage of emerging
opportunities and to minimize the effect of securities that are no longer option for the composite. The goal of the strategy is to
outperform an unmanaged buy and hold investment, reduce the effects of broad market declines and provide capital appreciation.
TACTICAL INTERNATIONAL EQUITY
Navigator Equity Hedged Fund Component Minimum $25,000
Navigator Equity Hedged Fund is an actively managed portfolio targeting U.S. equity styles, market capitalizations, and sectors
and international countries and regions. The objective of this strategy is to provide capital appreciation with a secondary goal of
capital preservation on a consistent basis by applying a disciplined quantitative investment approach. The strategy utilizes an
allocation to volatility to hedge the equity portion in an attempt to limit risk.
Navigator Global Equity ETF Component Minimum $50,000
The Navigator Global Equity ETF actively manages a portfolio targeting U.S. equity styles, market capitalizations, and sectors
coupled with exposure to international countries and regions. The strategy uses Clark Capital's proprietary relative strength
research to allow us to adapt to changing themes and is not biased to a traditional style, market capitalization approach or
international country or region. Blending U.S. and international investments may lower risk by reducing portfolio volatility. The
appropriate risk profile is achieved through careful allocation of the portfolio within established percentage ranges of styles,
sectors, and international securities. The strategy is implemented using exchange traded funds as they provide an efficient, low
cost alternative to traditional mutual funds and seeks to provide capital appreciation.
Navigator Global Tactical Component Minimum $25,000
The Navigator Global Tactical is constructed from a wide range of investment opportunities including domestic and foreign
equities, fixed income, real estate, commodities, precious metals and currencies. The objective is to provide investors with
consistent, competitive investment returns over time by tactically capitalizing on a broad range of global market opportunities.
The strategy seeks to provide capital appreciation through an unconstrained tactical allocation methodology in an effort to lower
portfolio volatility and increase returns. The unconstrained investment mandate is designed to allow for the efficient allocation
of risk capital globally to opportunities where potential returns are identified and seeks to provide the flexibility to avoid declining
markets or asset classes. The portfolio
invests in exchange-traded funds which provide diversification, limit specific security
risk, and provide tax efficiencies. The strategy seeks to provide capital appreciation.
Navigator International Opportunity Component Minimum $25,000
Navigator International Opportunity invests in international countries and regions in a vigorous and creative “explore” approach
which seeks to provide performance through strategic rotation among equity securities of foreign countries and regions. The
strategy has an unconstrained asset allocation policy and is allocated to international markets and regions including those of
developed countries and emerging markets that appear to have the potential for producing strong performance in the near future.
The portfolio is actively managed; security weightings are adjusted to take advantage of emerging market opportunities as they
arise and to harvest gains as they mature. The portfolio invests in exchange traded funds which provide diversification, limit
specific security risk, and provide tax efficiencies. The strategy seeks to provide capital appreciation.
ALTERNATIVE DIVERSIFIERS
Navigator Alternative Component Minimum $25,000
($10,000 in PUMA)
Navigator Alternative is constructed from a wide range of investment opportunities including long and short, Allocation among
U.S. equity, international equity, U.S. fixed income, international fixed income, real estate, commodities and precious metals,
currencies, energy and absolute/hedge strategies. The objective is to provide investors with capital appreciation independent of
the direction of the traditional equity markets. The use of alternative investments in concert with traditional assets in a total
investment plan may result in lower portfolio volatility and increased returns due to the increase in portfolio diversity and the
lack of correlation between alternative and traditional investments. Exchange traded funds are utilized when possible as they
may provide diversification, limit specific security risk, and provide tax efficiencies. Mutual funds may also be utilized. The
portfolio has an unconstrained asset allocation policy and seeks capital appreciation by applying a disciplined quantitative
investment approach that is non-correlated to the equity markets.
Navigator Fixed Income Total Return Component Minimum $25,000
Navigator Fixed Income Total Return is designed to maximize total return by rotational management of a fixed income portfolio
invested in low quality bonds (high-yield), high quality corporate and government bonds, short-term treasuries. The strategy
seeks to take advantage of the performance differential between segments of the bond market under different market conditions.
Through investment in segments of the fixed income market believed to be the strongest performer in the near term, the portfolio
may have the opportunity to outperform the broad bond market without exposure to the risk of the equity market. Active
management supported by in-depth, internally generated research seeks to pursue superior performance results with greater
consistency and lower volatility of returns. The portfolio invests in exchange traded funds and mutual funds targeting high yield
corporate, investment grade corporate, government, government agency and treasury fixed income sectors. The strategy has an
unconstrained allocation policy. The goal of the strategy is capital preservation while outperforming an unmanaged buy and hold
investment.
Navigator Tactical Fixed Income Fund Component Minimum $25,000
Clark Capital serves as advisor to the Navigator Tactical Fixed Income Fund, which is an open-end investment company. The
investment management services we provide to the fund mirror the investment philosophy, investment process, and security
selection of the Navigator Fixed Income Total Return portfolio. Additional information about the Navigator Mutual Funds is
available in the Funds’ prospectus and SAI, which is available on the Funds’ website (www.navigatorfund.com) or on the SEC’s
EDGAR database.
Portfolios Utilizing Global Equity ETF Separate Account Strategy
Navigator Global Balanced 20-80 Component Minimum $100,000
Navigator Global Balanced 20-80 strategy consists of portfolios with a 20% allocation to equity and 80% to fixed income. The
portfolio provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively
managed fixed income component seeking to lower risk and reduce portfolio volatility. The 20% allocation to equity allocation
utilizes the Navigator Global Equity ETF strategy which invests in exchange traded funds in U.S. equity styles, market
capitalizations and styles, and sectors and industry groups and international countries and regions. The 80% fixed income
allocation utilizes the Navigator Fixed Income Total Return strategy which has an unconstrained allocation policy targeting high
yield corporate, investment grade corporate, government, government agency, treasury fixed income sectors. The strategy seeks
to provide preservation of capital.
Navigator Global Balanced 40-60 Component Minimum $100,000
Navigator Global Balanced 40-60 strategy consists of portfolios with a 40% allocation to equity and 60% to fixed income. The
portfolio provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively
managed fixed income component seeking to lower risk and reduce portfolio volatility. The equity allocation invests in the
Navigator Global Equity ETF strategy which invests in exchange traded funds in U.S. equity styles, market capitalizations and
factors, sectors and industry groups and international countries and regions. The fixed income allocation utilizes the Navigator
Fixed Income Total Return Strategy. The fixed income allocation has an unconstrained allocation policy targeting high yield
corporate, investment grade corporate, government, government agency, and treasury fixed income sectors and cash and cash
equivalents/money markets. The strategy seeks to provide growth of capital.
Navigator Global Balanced 60-40 Component Minimum $100,000
Navigator Global Balanced 60-40 consists of portfolios with a 60% allocation to equity and 40% to fixed income. The portfolio
provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively managed fixed
income component seeking to lower risk and reduce portfolio volatility. The equity allocation invests in the Navigator Global
Equity ETF strategy which invests in exchange traded products in U.S. equity styles, market capitalizations and styles, and sectors
and industry groups and international countries and regions. The fixed income allocation utilizes the Navigator Fixed Income
Total Return Strategy. The fixed income allocation has an unconstrained allocation policy targeting high yield corporate,
investment grade corporate, government, government agency and treasury fixed income sectors. The strategy seeks to provide
growth of capital.
Navigator Global Balanced 80-20 Component Minimum $100,000
Navigator Global Balanced 80-20 strategy consists of portfolios with an 80% allocation to equity and 20% to fixed income.
The portfolio provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively
managed fixed income component seeking to lower risk and reduce portfolio volatility. The equity allocation invests in the
Navigator Global Equity ETF strategy which invests in exchange traded funds in U.S. equity styles, market capitalizations and
styles, and sectors and industry groups and international countries and regions. The fixed income allocation utilizes the
Navigator Fixed Income Total Return Strategy. The fixed income allocation has an unconstrained allocation policy targeting
high yield corporate, investment grade corporate, government, government agency and treasury fixed income sectors. The
strategy seeks to provide growth of capital.
Hedged Portfolios May Utilize the Navigator Equity Hedged Fund Based on Account Minimums Shown in Chart Below
Navigator Global Balanced 20-80 Hedged Component Minimum. See Chart Below.
Navigator Global Balanced 20-80 Hedged strategy consists of portfolios with a 20% allocation to equity and 80% to fixed income.
The portfolio provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively
managed fixed income component seeking to lower risk and reduce portfolio volatility. The equity allocation utilizes the
Navigator Equity Hedged Fund in an attempt to mitigate downside risk. The fixed income allocation utilizes the Navigator
Fixed Income Total Return Strategy which has an unconstrained allocation policy targeting high yield corporate, investment
grade corporate, government, government agency and treasury fixed income sectors. The portfolio seeks to provide growth of
capital.
Navigator Global Balanced 40-60 Hedged Component Minimum. See Chart Below.
Navigator Global Balanced 40-60 Hedged strategy consists of portfolios with a 40% allocation to equity and 60% to fixed income.
The portfolio provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively
managed fixed income component seeking to lower risk and reduce portfolio volatility. The equity allocation invests in the \
Navigator Equity Hedged Fund in an attempt to mitigate downside risk. The fixed income allocation utilizes the Navigator Fixed
Income Total Return Strategy. The fixed income allocation has an unconstrained allocation policy targeting high yield corporate,
investment grade corporate, government, government agency and treasury fixed income sectors. The portfolio seeks to provide
growth of capital.
Navigator Global Balanced 60-40 Hedged Component Minimum. See Chart Below.
Navigator Global Balanced 60-40 Hedged strategy consists of portfolios with a 60% allocation to equity and 40% to fixed income.
The strategy provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively
managed fixed income component seeking to lower risk and reduce portfolio volatility. The equity allocation invests in the
Navigator Equity Hedged Fund in an attempt to mitigate the downside risk. The fixed income allocation utilizes the Navigator
Fixed Income Total Return Strategy. The fixed income allocation has an unconstrained allocation policy targeting high yield
corporate, investment grade corporate, government, government agency and treasury fixed income sectors. The portfolio seeks
to provide growth of capital.
Navigator Global Balanced 80-20 Hedged Component Minimum. See Chart Below.
Navigator Global Balanced 80-20 Hedged strategy consists of portfolios with an 80% allocation to equity and 20% to fixed
income. The portfolio provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an
actively managed fixed income component seeking to lower risk and reduce portfolio volatility. The equity allocation is invested
in the Navigator Equity Hedged Fund. The fixed income allocation utilizes the Navigator Fixed Income Total Return Strategy.
The fixed income allocation has an unconstrained allocation policy targeting high yield corporate, investment grade corporate,
government, government agency and treasury fixed income sectors.
Global Balanced Hedged
Portfolio Options Component Minimum
80% equity/20% fixed
income
Navigator Global Balanced Hedged Separate Account Allocation: $100,000
Navigator Equity Hedged Mutual Fund Allocation: $25,000
60% equity/40% fixed
income
Navigator Global Balanced Hedged Separate Account Allocation: $100,000
Navigator Equity Hedged Mutual Fund Allocation: $25,000
40 equity/60% fixed
income
Navigator Global Balanced Hedged Separate Account Allocation: $100,000
Navigator Equity Hedged Mutual Fund Allocation: $25,000
20% equity/80% fixed
income
Navigator Global Balanced Hedged Separate Account Allocation: $100,000
Navigator Equity Hedged Mutual Fund Allocation: $25,000
TRADITIONAL BALANCED SOLUTIONS
Navigator Traditional Balanced 60-40 Component Minimum $150,000
Navigator Traditional Balanced 60-40 is a portfolio consisting of 60% global equity and 40% U.S. fixed income. The strategy
provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively managed fixed
income component. The equity allocation invests in exchange traded products in U.S. equity styles, market capitalizations and
styles, and sectors and industry groups and international countries and regions. The fixed income allocation invests in individual
fixed income securities, exchange traded products and mutual funds. Blending U.S. and international investments and fixed
income may lower risk by reducing portfolio volatility. The strategy seeks to provide growth of capital with a secondary objective
of current income on a consistent basis by applying a disciplined quantitative investment approach.
Navigator Traditional Balanced 60-40 Hedged Component Minimum $150,000
Navigator Traditional Balanced 60-40 Hedged is a portfolio consisting of 60% global equity and 40% U.S. fixed income. The
strategy provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively
managed fixed income component. The equity allocation invests in exchange traded products in U.S. equity styles, market
capitalizations and styles, and sectors and industry groups and international countries and regions. The fixed income allocation
invests in individual fixed income securities, exchange traded products and mutual funds. Blending U.S. and international
investments and fixed income may lower risk by reducing portfolio volatility. A hedging strategy is incorporated into the portfolio
through the Navigator Equity Hedged Fund. The strategy seeks to provide growth of capital with a secondary objective of current
income on a consistent basis by applying a disciplined quantitative investment approach.
Navigator Traditional Balanced 70-30 Component Minimum $150,000
Navigator Traditional Balanced 70-30 is a portfolio consisting of 70% global equity and 30% U.S. fixed income. The strategy
provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively managed fixed
income component. The equity allocation invests in exchange traded products in U.S. equity styles, market capitalizations and
styles, and sectors and industry groups and international countries and regions. The fixed income allocation invests in individual
fixed income securities, exchange traded products and mutual funds. Blending U.S. and international investments and fixed
income may lower risk by reducing portfolio volatility. The strategy seeks to provide growth of capital with a secondary objective
of current income on a consistent basis by applying a disciplined quantitative investment approach.
Navigator Traditional Balanced 70-30 Hedged Component Minimum $150,000
Navigator Traditional Balanced 70-30 Hedged is a portfolio consisting of 70% global equity and 30% U.S. fixed income. The
strategy provides targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively
managed fixed income component. The equity allocation invests in exchange traded products in U.S. equity styles, market
capitalizations and styles, and sectors and industry groups and international countries and regions. The fixed income allocation
invests in individual fixed income securities, exchange traded products and mutual funds. Blending U.S. and international
investments and fixed income may lower risk by reducing portfolio volatility. Hedging is incorporated into the portfolio through
the Navigator Managed Volatility Fund. The strategy seeks to provide growth of capital with a secondary objective of current
income on a consistent basis by applying a disciplined quantitative investment approach.
Navigator Traditional Balanced 80-20 Component Minimum $150,000
Navigator Traditional Balanced 80-20 is a portfolio consisting of 80% equity and 20% fixed income. The strategy provides
targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively managed fixed income
component. The equity allocation invests in exchange traded products in U.S. equity styles, market capitalizations and styles,
and sectors and industry groups and international countries and regions. The fixed income allocation invests in individual fixed
income securities, exchange traded products and mutual funds. Blending U.S. and international investments and fixed income
may lower risk by reducing portfolio volatility. The strategy seeks to provide growth of capital with a secondary objective of
current income on a consistent basis by applying a disciplined quantitative investment approach.
Navigator Traditional Balanced 80-20 Hedged Component Minimum $150,000
Navigator Traditional Balanced 80-20 is a portfolio consisting of 80% equity and 20% fixed income. The strategy provides
targeted exposure to the U.S. equity market coupled with targeted international exposure and an actively managed fixed income
component. The equity allocation invests in exchange traded products in U.S. equity styles, market capitalizations and styles,
and sectors and industry groups and international countries and regions. The fixed income allocation invests in individual fixed
income securities, exchange traded products and mutual funds. Blending U.S. and international investments and fixed income
may lower risk by reducing portfolio volatility. Hedging is incorporated into the portfolio through the Navigator Equity Hedged
Fund. The strategy seeks to provide growth of capital with a secondary objective of current income on a consistent basis by
applying a disciplined quantitative investment approach.
FEES AND COMPENSATION
As a client, you should be aware that the wrap fee charged by Clark Capital could be higher (or lower) than those charged by
others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower rates. A client
may be able to obtain some or all of the types of services available through Clark Capital’s Wrap Fee Programs on an individual
basis through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or higher
than the annual fees shown below. The factors that impact the relative cost to clients in Clark Capital’s Wrap Fee Programs
include: the size of the account, the investment strategies selected for the account, customized options selected by the client (i.e.,
active core allocation, passive core allocation, hedging), and the level of trading activity in the client’s account with the custodian
(the lower the activity, the less the client may benefit). For more information on the cost of trades that are traded away from the
custodian, please see “Brokerage Practices” below.
Investment Advisory Fees
Clients pay a fee for our investment advisory services (“Investment Advisory Fee”). The range of Investment Advisory Fees
you pay for our services are shown in the annual fee schedules below. The services we provide in exchange for our Investment
Advisory Fee are also described below.
The Investment Advisory Fee is deducted quarterly in advance from your account by your custodian and is based on the assets
in your account at the close of the prior quarter. At the inception of our relationship with you and each quarter thereafter, we
notify your custodian of the amount of the Investment Advisory Fee due and payable to us. The custodian does not validate or
check the Investment Advisory Fee or its calculation or the assets on which the fee is based. Your custodian will deduct the fee
from your account or, if you have more than one account, you may arrange to have fees paid from an account you designate with
our approval.
Each month, you will receive a statement directly from your custodian showing all transactions, positions and credits/debits into
or from your account, including the Investment Advisory Fee deducted from your account. Quarterly, you will receive a statement
from us that will show the allocation of your account, performance, portfolio value and changes in portfolio value, among other
account details. You should compare the statements you receive from your custodian with the quarterly statement from Clark
Capital and notify us immediately if you find discrepancies, or if you do not receive the monthly custodial statements.
The Investment Advisory Fee will not be adjusted if assets are withdrawn after the inception of a quarter. When you contribute
additional assets to your account after the initial subscription date, the Investment Advisory Fee will be increased on a pro rata
basis during the quarter in which additional assets are received. Notice of cancellation or termination of an account must be
received within ten days of quarterly billing to request a refund. If a client’s portfolio has an investment allocation to a mutual
fund managed by Clark Capital, the fees will be adjusted to accommodate the investment advisory fee also to be paid by the
mutual fund to Clark Capital to ensure that clients are not paying additional advisory fees to Clark Capital.
The Investment Advisory Fee covers the following services provided by Clark Capital: investment advice; portfolio allocations;
account processing; client consultation; detailed account statements; and other services. The Investment Advisory Fee is also
inclusive of custodial, clearing and brokerage services. The Investment Advisory Fee is a flat fee based on the amount of assets
the client has under management and the level of the account according to the schedules below, subject to certain exceptions.
The Investment Advisory Fee encompasses all portfolio components, except certain management fees and other operating fees
and expenses incurred by mutual funds and exchange traded funds as disclosed in the prospectus for such funds. The Investment
Advisory Fee may be negotiable.
Unified Solutions Fees
Unified Solutions Active Core Option
From:
To:
Level I
Level II
Level III
Level IV
Level V
Account minimum $500,000 0.85% 1.00% 1.15% 1.15% 1.15%
$500,001 $750,000 0.75% 0.95% 1.10% 1.10% 1.10%
$750,001 $1,000,000 0.70% 0.85% 1.00% 1.00% 1.00%
Over $1,000,000 0.60% 0.80% 0.90% 0.90% 0.90%
Account levels are based upon risk determination and investment objectives.
Unified Solutions Passive Core Option
From:
To:
Level 0
Level I
Level II
Level III
Level IV
Level V
Account minimum
$250,000
0.70%
0.85%
1.00%
1.15%
1.15%
1.15%
$250,001 $500,000 0.60% 0.80% 0.90% 1.05% 1.05% 1.05%
$500,001 $750,000 0.50% 0.70% 0.85% 1.00% 1.00% 1.00%
$750,001 $1,000,000 0.45% 0.60% 0.75% 0.90% 0.90% 0.90%
Over $1,000,000 0.40% 0.55% 0.70% 0.85% 0.85% 0.85%
Account levels are based upon risk determination and investment objectives.
PUMA and Separate Account Fees
With a PUMA, the client may choose to incorporate investment strategies featuring one or more of the account components listed
in Item 4 of this Wrap Fee Brochure which utilize different investment styles, strategies, and investment vehicles into one
managed account. The account must have a minimum size of $50,000 and must incorporate two or more components. The
Advisory fee will be a combination of the individual components’ fee schedules as set forth below:
All Cap Core U.S. Equity International Opportunity
All Cap Core U.S. Equity Hedged Small Cap Core U.S. Equity
Alternative Strategy SMID Cap Core U.S. Equity
Global Equity ETF Traditional Balanced
Global Tactical Traditional Balanced Hedged
Global Opportunity U.S. Sector Opportunity
High Dividend Equity U.S. Style Opportunity
High Dividend Equity with Options or Customized
International Equity/ADR
From:
To:
Account minimum $500,000 1.10%
$500,001 $750,000 1.00%
$750,001 $1,000,000 0.95%
Over $1,000,000 0.85%
Global Equity ETF Hedged
From:
To:
Account minimum
$500,000
1.05%
$500,001 $750,000 0.95%
$750,001 $1,000,000 0.90%
Over $1,000,000 0.80%
Global Balanced
From:
To:
Account minimum
$500,000
0.50%
$500,001 $750,000 0.40%
$750,001 $1,000,000 0.30%
Over $1,000,000 0.25%
* Using Separate Account Allocation of Fixed Income Total Return
Global Balanced Hedged*
From:
To:
Account minimum
$500,000
0.00%
$500,001 $750,000 0.00%
$750,001 $1,000,000 0.00%
Over $1,000,000 0.00%
* Using the mutual fund Navigator Equity Hedged Fund and Navigator Tactical Fixed Income Fund.
Clark Capital receives a fee for management of the funds from the Fund.
Fixed Income Total Return
From:
To:
Account minimum
$500,000
0.85%
$500,001 $750,000 0.70%
$750,001 $1,000,000 0.60%
Over $1,000,000 0.50%
International Equity Strategic Beta U.S. Equity Strategic Beta
U.S. Equity Income Strategic Beta
From:
To:
Account minimum
$500,000
0.50%
$500,001 $750,000 0.45%
$750,001 $1,000,000 0.40%
Over $1,000,000 0.35%
International Equity Core U.S. Equity Income Core
U.S. Equity Core
From:
To:
Account minimum
$500,000
0.75%
$500,001 $750,000 0.70%
$750,001 $1,000,000 0.65%
Over $1,000,000 0.60%
MultiStrategy Taxable Fixed Income
Taxable Fixed Income Strategic Beta Tax-Free Fixed Income
Tax-Free Fixed Income Core
From:
To:
Account minimum
$500,000
0.50%
$500,001 $1,000,000 0.40%
$1,000,001 $3,000,000 0.30%
Over $3,000,000 0.25%
Holding Accounts
Asset Valuation:
Account minimum
0.35%
Option Enhancement on Concentrated Equity
Asset Valuation:
Variable
0.75%
See “Additional Fees” below for information on other potential fees.
ADDITIONAL FEES
The Investment Advisory Fees payable to us do not include all the fees you will pay when we manage your account. The following
fees may be assessed depending upon your investment choice: (1) advisory fees and administrative fees charged by mutual funds
and exchange traded products including the mutual funds and exchange traded products managed by Clark Capital (such as
distribution fees, servicing fees, operating expenses and deferred sales charges); (2) wire transfer and electronic fund processing
fees; (3) SEC or other regulatory fees;; or (4) other fees mandated by law.
Clark Capital serves as the investment adviser to the Navigator Mutual Funds. At times, and as described in this Wrap Fee
Brochure, Clark Capital may invest a portion of the assets managed for Clark Capital Wrap Fee Program clients in one or more
of the Navigator Mutual Funds. In those instances, the assets invested in a Navigator Mutual Fund will be subject to the applicable
management fee imposed on Fund assets, as described in the Funds’ prospectus. The fee schedules below reflect the fees stated
in each Fund’s prospectus as of the date of this Brochure. Navigator Mutual Fund management fees are not negotiable but are
reviewed by the Funds’ Board of Trustees on an annual basis.
Fund Name Annual Management Fee
Navigator Equity Hedged Fund 0.75%
Navigator Tactical Fixed Income Fund 0.82%
Navigator Tactical U.S. Allocation Fund 0.85%
Navigator Ultra Short Bond Fund 0.30%
Navigator Tactical Investment Grade Bond Fund 0.85%
The fee schedules for the Navigator Tactical Fixed Income Fund, the Navigator Tactical U.S. Allocation Fund, and the Navigator
Tactical Investment Grade Bond Fund include management fee breakpoints, which reduce Clark Capital’s total management fees
when the net assets in the aforementioned funds exceeds the thresholds in the table below:
Portion of Net Assets Annual Management Fee
Less than $4.5 billion 0.85%
Greater than $4.5 billion and less than or equal to $5.5 billion 0.80%
Greater than $5.5 billion 0.75%
In order to address the economic incentive that Clark Capital may have in investing Clark Capital Wrap Fee Program client
accounts in the Funds, the Investment Advisory Fee payable under Clark Capital’s Wrap Fee Program is reduced to offset the
management fee that Clark Capital will receive from the Funds. Assets invested in a Navigator Mutual Fund will also be subject
to the other expenses described in the Funds’ prospectuses, including any applicable distribution fees, administrative expenses,
and other Fund operating expenses. Please refer to the Navigator Mutual Funds’ prospectuses and statements of additional
information for information on additional fees and expenses associated with those investments.