57 River Street,

Suite 301
Wellesley, MA 02481


Important Disclaimers

Empirical Asset Management, LLC ("EAM") is a Registered Investment Advisor ("RIA"), located in the Commonwealth of Massachusetts. EAM provides investment advisory and related services for clients nationally. EAM will maintain all applicable registration and licenses as required by the various states in which EAM conducts business, as applicable. EAM renders individualized responses to persons in a particular state only after complying with all regulatory requirements, or pursuant to an applicable state exemption or exclusion.

Terms of Use

Please read these terms and conditions of use (“Terms”) carefully before using the website located at empiricalam.com (“Website”) or any of the information or services provided by Empirical Asset Management, LLC (collectively “EAM”, “we”, “our”, “us”) in connection with the Website. By using the Website, you acknowledge that you have read and understood these Terms and accept to be legally bound by them. If you do not accept and agree to these Terms, you are not an authorized user of the Website or any of the information or services provided by EAM in connection with the Website and should promptly terminate all use thereof. The terms “you” and “your” mean you and any entity you may represent in connection with the use of the Website. You may use your browser to download or print a copy of these Terms for your records.

EAM reserves the right to change, modify, add or remove portions of these Terms at any time for any reason. We suggest that you review these Terms periodically for changes. Such changes shall be effective immediately upon posting. You acknowledge that by accessing our Website after we have posted changes to these Terms, you are agreeing to these Terms as modified.

These Terms were last updated on December 15, 2022.

Risk Disclosure

Different types of investments involve varying degrees of risk. Therefore, it should not be assumed that future performance of any specific investment or investment strategy will be profitable.

Asset allocation may be used in an effort to manage risk and enhance returns. It does not, however, guarantee a profit or protect against loss. Performance of the asset allocation strategies depends on the underlying investments.

This website is intended to provide general information about EAM and its services. It is not intended to offer or deliver investment advice in any way. Information regarding investment services are provided solely to gain an understanding of our investment philosophy, our strategies and to be able to contact us for further information.

Market data, articles and other content on this website are based on generally available information and are believed to be reliable. EAM does not guarantee the accuracy of the information contained in this website. The information is of a general nature and should not be construed as investment advice.

Please remember that it remains your responsibility to advise EAM, in writing, if there are any changes in your personal/financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services, if you would like to impose, add, or to modify any reasonable restrictions to our investment advisory services.

EAM will provide all prospective clients with a copy of our current Form ADV, Part 2A ("Disclosure Brochure"), Form ADV Part 2B, which is the Brochure Supplement for each advisory person supporting a particular client, and the Form ADV Part 3 (Client Relationship Summary or Form CRS). You may obtain a copy of these disclosures on the SEC website at http://adviserinfo.sec.gov or you may Contact Us to request a free copy via .pdf or hardcopy.

Privacy Disclosures

EAM is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described in our Privacy Policy.

EAM does not collect personal non-public information through this website; however, the Advisor may collect information from you on application forms, agreements, profile or investment policy statements, and other documents received or processed in relation to services we provide. We also may collect information from other sources.

We do not respond to "do not track" requests because we do not track you over time or across third party websites to provide targeted advertising. We may track you across our website to help us improve our content.

We may use "cookies" and similar online technologies to keep, and sometimes track, information about you regarding your usage of our website. Cookies are small data files that are sent to your browser or related software from a Web server and stored on your device. Cookies help us to collect information about your usage of our website, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site, such as the browser used. You can refuse to store or delete cookies by configuring your web browser settings. Most browsers and mobile devices have their own settings to manage cookies. If you refuse a cookie when on our website, or if you delete cookies, you may experience some inconvenience in your use of our website, such as having to re-configure preferences.

When you are on this website you may have the opportunity to click-through to other websites, including websites operated by unaffiliated third parties. These sites may collect nonpublic personal Information about you. We do not control sites operated by these entities and are not responsible for the information practices of these sites. This Privacy Policy does not address the information practices of other websites. The privacy policies of websites operated third parties are located on those sites.

For a copy of the EAM Privacy Policy, please Contact Us.

Email Disclosures

EAM often communicates with its clients and prospective clients through electronic mail (“email”) and other electronic means. Your privacy and security are very important to us. EAM makes every effort to ensure that email communications do not contain sensitive information. We remind our clients and others not to send EAM private information over email. If you have sensitive data to deliver, we can provide secure means for such delivery.

Please note: EAM does not accept trading or money movement instructions via email.

As a registered investment advisor, EAM emails may be subject to inspection by the Chief Compliance Officer (“CCO”) of EAM or the securities regulators.

If you have received an email from EAM in error, we ask that you contact the sender and destroy the email and its contents.

If you have any questions regarding our email policies, please Contact Us.

Social Websites

EAM may utilize third-party websites, including social media websites, blogs and other interactive content. EAM considers all interactions with clients, prospective clients and the general public on these sites to be advertisements under the securities regulations. As such, EAM generally retains copies of information that EAM or third-parties may contribute to such sites. This information is subject to review and inspection by the CCO of EAM or the securities regulators.

Information provided on these sites is for informational and/or educational purposes only and is not, in any way, to be considered investment advice nor a recommendation of any investment product. Advice may only be provided by EAM’s advisory persons after entering into an advisory agreement and provided EAM with all requested background and account information.

If you have any questions regarding our policies, please Contact Us.

*Morningstar Sustainability RatingTM

The Morningstar Sustainability RatingTM is intended to measure how well the issuing companies of the securities within a fund’s portfolio holdings are managing their financially material environmental, social and governance, or ESG, risks relative to the fund’s Morningstar Global Category peers.

The Morningstar Sustainability Rating calculation is a five -step process. First, each fund with at least 67% of assets covered by a company-level ESG Risk Score from Sustainalytics receives a Morningstar Portfolio Sustainability Score. The Morningstar Portfolio Sustainability Score is an asset-weighted average of company-level ESG Risk Scores. The Portfolio Sustainability Score ranges between 0 to 100, with a higher score indicating that a fund has, on average, more of its assets invested in companies with high ESG Risk.

Second, the Historical Sustainability Score is an exponential weighted moving average of the Portfolio Sustainability Scores over the past 12 months. The process rescales the current Portfolio Sustainability Score to reflect the consistency of the scores. The Historical Sustainability Score ranges between 0 to 100, with a higher score indicating that a fund has, on average, more of its assets invested in companies with high ESG Risk, on a consistent historical basis.

Third, the Morningstar Sustainability Rating is then assigned to all scored funds within Morningstar Global Categories in which at least thirty (30) funds receive a Historical Sustainability Score and is determined by each fund's Morningstar Sustainability Rating Score rank within the following distribution:

• High (highest 10%)

• Above Average (next 22.5%)

• Average (next 35%)

• Below Average (next 22.5%) and

• Low (lowest 10%)

Fourth, we apply a 1% rating buffer from the previous month to increase rating stability. This means a fund must move 1% beyond the rating breakpoint to change ratings. Fifth, we adjust downward positive Sustainability Ratings to funds with a with high ESG Risk scores. The logic is as follows:

• If Portfolio Sustainability score is above 40, then the fund receives a Low Sustainability Rating • If Portfolio Sustainability score is above 35 and preliminary rating is Average or better, then the fund is downgraded to Below Average

• If Portfolio Sustainability score is above 30 and preliminary rating is Above Average, then the fund is downgraded to Average

• If Portfolio Sustainability score is below 30, then no adjustment is made.

The Morningstar Sustainability Rating is depicted by globe icons where High equals 5 globes and Low equals 1 globe. Since a Sustainability Rating is assigned to all funds that meet the above criteria, the rating it is not limited to funds with explicit sustainable or responsible investment mandates.

Morningstar updates its Sustainability Ratings monthly. The Portfolio Sustainability Score is calculated when Morningstar receives a new portfolio. Then, the Historical Sustainability Score and the Sustainability Rating is calculated one month and six business days after the reported as-of date of the most recent portfolio. As part of the evaluation process, Morningstar uses Sustainalytics’ ESG scores from the same month as the portfolio as-of date.

**The Morningstar Star Rating is a proprietary data point that is quantitatively driven. Funds are rated from one to five stars based on how well the fund performed (after adjusting for risk and accounting for sales charges) in comparison to similar funds. Within each Morningstar Category, the top 10% of funds receive five-stars and the bottom 10% receives one-star. Funds are rated for up to three time periods –three-, five-, and ten-years– and these ratings are combined to produce an overall star rating, which is noted within the Report. Funds with less than three years of history are not rated. Morningstar Star Ratings are based entirely on a mathematical evaluation of past performance. Morningstar Star Ratings are in no way to be considered a buy or sell signal nor should be viewed as a statement of fact.

***Informa Investment Solutions, a subsidiary of Informa PLC, is a leading provider of solutions and custom services to financial institutions and investment professionals. For over 30 years, Informa Investment Solutions has supplied valuable data and offered tailored performance measurement, wealth management tools, reporting, and communications solutions to brokerages, money management firms, investment consultants, independent advisors and pension plan sponsors. We serve more than 1,300 clients and track data in our widely-used PSN database for more than 2,000 investment management firms and 12,000 products worldwide. For more information on Informa Investment Solutions, visit www.informais.com.

PSN, a division of Informa Investment Solutions Inc., maintains the world’s longest-running and most robust manager database, containing 12,000 institutional investment products reported by more than 2,000 managers. To be considered for 5-Star Top Guns status, an asset manager must have demonstrated the ability to deliver superior risk-adjusted returns over time relative to the appropriate benchmark. Specifically, PSN screens for an R-squared of 0.80 or greater relative to the style benchmark over the most recent five-year period ending date and returns greater than the benchmark for the three latest three-year rolling periods. Finally, products must have a five-year standard deviation equal to or less than the median for the peer group. The separate managed account products with the top ten returns for the latest three-year period then become Top Guns.

The information provided is for educational and informational purposes only and does not constitute investment advice and it should not be relied on as such. It should not be considered a solicitation to buy or an offer to sell a security. It does not take into account any investor's particular investment objectives, strategies, tax status or investment horizon. You should consult your attorney or tax advisor.

The views expressed in this commentary are subject to change based on market and other conditions. These documents may contain certain statements that may be deemed forward looking statements. Please note that any such statements are not guarantees of any future performance and actual results or developments may differ materially from those projected. Any projections, market outlooks, or estimates are based upon certain assumptions and should not be construed as indicative of actual events that will occur.

All information has been obtained from sources believed to be reliable, but its accuracy is not guaranteed. There is no representation or warranty as to the current accuracy, reliability or completeness of, nor liability for, decisions based on such information and it should not be relied on as such.

Index returns are unmanaged and do not reflect the deduction of any fees or expenses. Index returns reflect all items of income, gain and loss and the reinvestment of dividends and other income. You cannot invest directly in an Index.

No investment strategy or risk management technique can guarantee returns or eliminate risk in any market environment.

All investments include a risk of loss that clients should be prepared to bear. The principal risks of EAM strategies are disclosed in the publicly available Form ADV Part 2A.

Past performance shown is not indicative of future results, which could differ substantially.

Empirical Asset Management (“EAM”) is a registered investment advisor. Advisory services are only offered to clients or prospective clients where EAM and its representatives are properly licensed or exempt from licensure.