DISCLOSURE FOR CANADIAN CLIENTS

Important Information for Residents of Canada: SMART PORTFOLIOS, LLC markets to “permitted” prospective clients in the each of the provinces of Canada. Clients and prospective clients of SMART PORTFOLIOS, LLC that are residents in Canada are advised that SMART PORTFOLIOS, LLC operates under the International Adviser Exemption in Canada pursuant to National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations (“NI 31-103”). Such clients should be aware that: • SMART PORTFOLIOS, LLC is not registered as an adviser (portfolio manager) in any Canadian province or territory to provide advice on securities as contemplated in NI 31-103; • SMART PORTFOLIOS, LLC is not subject to the full regulatory requirements otherwise applicable under the securities legislation of any Canadian province or territory; • SMART PORTFOLIOS, LLC’s head office and principal place of business is located in the United States of America at 17865 Ballinger Way, NE, Lake Forest Park, WA 98155; • All or substantially all of SMART PORTFOLIOS, LLC’s assets may be situated outside of Canada; and • There may be difficulty enforcing legal rights against SMART PORTFOLIOS, LLC because of the above. Because SMART PORTFOLIOS, LLC operates under exemptions from the investment adviser registration requirements under applicable Canadian securities law, clients should be aware that SMART PORTFOLIOS, LLC is restricted from acting as an investment adviser in respect of securities of Canadian issuers. For more information on this disclosure, and our ADV, Click Here

MORE INFORMATION FOR CANADIAN CLIENTS

Smart Portfolios, LLC is the brand under which the professionals of our company collaborate to provide financial and investment advisory, risk management, and financial planning to selected clients. Smart Portfolios, LLC is a wholly owned subsidiary of Shield Holdings, LLC, located in Seattle, Washington, USA. As such, Smart Portfolios, LLC is registered in a category of registration, or operates under an exemption from registration, under the securities legislation of the foreign jurisdiction in which its head office or principal place of business is located, that permits it to carry on the activities in that jurisdiction that registration as an adviser would permit it to carry on in the local jurisdiction.

Smart Portfolios, LLC is a U.S. SEC registered investment advisor. Smart Portfolios, LLC provides portfolio management services, domestic and cross-border financial planning solutions. Smart Portfolios, LLC may act as an International Adviser, and rely on the Canada Foreign Advisor Exemption to work with Permitted Clients and will notify the Regulatory Authorities in Canada on an annual basis of permitted client-based activities. Advisory services are only offered to clients or prospective clients where Smart Portfolios, LLC and its representatives are properly licensed or exempt from licensure.

All Permitted Client assets will be custodied in Canada, through custodial agreements with Canadian financial institutions, or Schedule III banks that are subject to the jurisdiction of the Government of Canada. No advice may be rendered by a Smart Portfolios, LLC company unless a client service agreement is in place.

As at the end of its most recently completed financial year, not more than 10% of the aggregate consolidated gross revenue of the adviser, Smart Portfolios, LLC, its affiliates, and its affiliated partnerships, was derived from the portfolio management activities of the adviser, its affiliates and its affiliated partnerships in Canada. Smart Portfolios, LLC is not registered in the local jurisdiction to provide advice, and its head office is in Lake Forest Park, Washington USA. All or substantially all Smart Portfolios, LLC assets are situated outside of Canada, and there may be difficulty enforcing legal rights against the adviser because of the above. Smart Portfolios, LLC has an adviser’s agent, Roy Berg International Tax Law, Suite 1500, 205 5th Ave SW, Calgary, AB Canada, T2P 2V7. and Smart Portfolios, LLC has submitted to the security’s regulatory authority a completed Form 31-103F2 Submission to jurisdiction and appointment of agent for service. The Firm Brochure, Privacy Policy and Business Continuity Plan are available upon request. Click Here to view the firm’s Brochure. A copy of our Client Relationship Agreement Part 3 may be found as filed with the SEC. Advisory services are only offered to clients or prospective clients where Smart Portfolios, LLC, and its representatives are properly licensed or exempt from licensure. In some cases, Smart Portfolios, LLC, and its advisors may offer fee-only financial planning services.