Our commitment to you.
As a client of Five Dimensions Invest, you’ve entrusted to our care not only your financial assets but certain personal and financial data as well. We recognize that your relationship with us is based on trust and that you expect us to act responsibly and in your best interests. Because your personal and financial data is your private information, we hold ourselves to the highest standards in its safekeeping and use. Five Dimensions Investment Management may serve as the investment advisor or subadvisor to an investment company registered under the Investment Company Act of 1940 (each, a “Fund”), and as such maintains shareholder information for each Fund under management. It is the policy of Five Dimensions Investment Management to adopt each Fund Privacy Policy, which shall be incorporated by reference into this Policy.
We collect nonpublic personal information about our clients from information we receive from your applications or other forms relating to establishing an account with us. In addition, we obtain information in connection with executing transactions on your behalf and dealing with your custodian.
All information regarding client identity, security holdings and financial status will be kept strictly confidential. We maintain physical, electronic and operational safeguards to protect nonpublic personal information about our clients.
We do not disclose any of your nonpublic personal information unless
(1) you request or authorize it,
(2) we have been advised that your accountant, attorney, or consultant is requesting the information on your behalf, or
(3) we are legally required to provide the information to a governmental agency.
We sometimes find it necessary to provide personal information about you to entities that provide a service on behalf of Five Dimensions Investment Management, such as firms that provide reports or custody services on behalf of our clients. These companies are expected to maintain strict privacy and confidentiality policies.
If you have any questions about our privacy policies or our commitment to you to safeguard private information, please contact us at 321-593-1555
The Five Dimensions invest collects non-public information about you from the following sources:
• Information we receive about you on applications or other forms;
• Information you give us orally; and
• Information about your transactions with us or others.
We do not disclose any non-public personal information about our shareholders or former shareholders without the shareholder’s authorization, except as permitted by law or in response to inquiries from governmental authorities. We may share information with affiliated and unaffiliated third parties with whom we have contracts for servicing the Five Dimensions U.S. Small Cap Strategy. We will provide unaffiliated third parties with only the information necessary to carry out their assigned responsibilities. We maintain physical, electronic and procedural safeguards to guard your non-public personal information and require third parties to treat your non-public personal information with the same high degree of confidentiality.
In the event that you are invested in the strategy through a financial intermediary, including, but not limited to, an advisor, a broker-dealer, bank, or trust company, the privacy policy of your financial intermediary would govern how your non-public personal information would be shared by those entities with unaffiliated third parties
Five Dimensions Investment Management, LLC is closed, no longer a registered investment adviser or family office. All information contained herein is for general informational purposes or historical purposes only and does not constitute a solicitation or an offer to sell investment advisory services in any jurisdiction. Performance shown represents results achieved at prior firms. Past performance does not guarantee future results. Five Dimensions has complied fully with the recordkeeping requirements of Rule 204-2(a)(16)(the “rule”) of the Advisers Act, along with the detailed regulatory requirements of other parts, and the CFAI standards, including its Code of Ethics, Standards of Professional Conduct and Global Investment Performance Standards.
. The 5 Dimensions U.S. Small Cap strategy (the “Strategy”) began in December 2010 and was managed by First Midwest Bank until February 2022 at which time it was transitioned to Five Dimensions Investment Management. Between August 2025 and December 2025, accounts and strategies were unwound, terminated, or transferred. Jason R. Bulinski has served as the portfolio manager of the Strategy since December 2010. At all times during his tenure as portfolio manager or chief investment officer, Mr. Bulinski has had ultimate decision-making authority with respect to the Strategy. Returns are presented gross as net of management fee provides immaterial differences in any decision making or conclusion post hoc and include the reinvestment of all dividends. Historical net of fee performance if calculated would use the highest fee of a 1.00% annual management fee. Past performance does not guarantee future results.
Five Dimensions has complied fully with the recordkeeping requirements of Rule 204-2(a)(16)(the “rule”) of the Advisers Act, along with the detailed regulatory requirements of other parts, and the CFAI standards, including its Code of Ethics, Standards of Professional Conduct and Global Investment Performance Standards. Past performance is not indicative of future results.
HISTORY
Five Dimensions Investment Management LLC, a registered investment adviser (July 27, 2022- August 7, 2025)
Five Dimensions Investment Management LLC, a Family Office (August 7, 2025- December 23, 2025)-Executed MAA/IMSA
Five Dimensions Investment Management LLC, a Family Office (February 18, 2022- July 27, 2022, conversion executed MAA/IMSA)
First Midwest Bank, Regional Bank $15B AUM, Chief Investment Officer
Five Dimensions Investment Management, LLC was defined as an independent investment management firm that is not affiliated with any parent organization. Performance shown prior to 18 February 2022 represents results achieved solely by Jason R. Bulinski, CFA while he was part of First Midwest Bank, a division of Old National Bank. Policies for valuing portfolios, calculating performance, and preparing compliant presentations are available upon request. Jason R. Bulinski, CFA took over the management of the small cap strategy December 1, 2010 and had sole discretion and full discretion of the small cap strategy and sub-advisory relationship with Premier Asset Management. The last full verification report is available on the website and upon request. Verification assesses whether (1) the firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the firm’s policies and procedures are designed to calculate and present performance in compliance with the GIPS standards. Verification does not ensure the accuracy of any specific composite presentation.
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