General Disclosure 2022

Topturn Capital LLC is an SEC registered investment advisor headquartered in Monterey, California. Topturn and its representatives are in compliance with the current registration and notice filing requirements imposed upon SEC registered investment advisors by those states in which Topturn maintains clients. Topturn may only transact business in those states in which it is notice filed, or qualifies for an exemption or exclusion from notice filing requirements. Topturn’s web site is limited to the dissemination of general information regarding its investment advisory services to United States residents residing in states where providing such information is not prohibited by applicable law. Accordingly, the publication of Topturn’s web site on the Internet should not be construed by any consumer and/or prospective client as a solicitation to effect, or attempt to effect transactions in securities, or the rendering of personalized investment advice for compensation. Information on this Internet site should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advice. For information pertaining to the registration status of Topturn, please contact the United States Securities and Exchange Commission on their web site at www.adviserinfo.sec.gov. A copy of Topturn’s current written disclosure statement discussing Topturn’s business operations, services, and fees is available from Topturn upon written request. Topturn does not make any representations as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Topturn’s web site or incorporated herein, and takes no responsibility therefore.

ACCESS TO THIS WEB SITE IS PROVIDED FOR INFORMATIONAL PURPOSES ONLY AND WITHOUT ANY WARRANTIES, EXPRESSED OR IMPLIED, REGARDING THE ACCURACY, COMPLETENESS, TIMELINESS, OR RESULTS OBTAINED FROM ANY INFORMATION POSTED

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