Disclosure of Portfolio Holdings
The Trust has adopted reasonable policies and procedures designed to prevent selective disclosure of the Funds’ portfolio holdings to third parties. Each Fund discloses its top ten portfolio holdings on a quarterly basis approximately fifteen (15) business days after quarter-end by posting the information on the Trust website. Each Fund also discloses its portfolio holdings in reports to shareholders within 60 days of the end of the fund's fiscal semi-annual period ended and in filings with the SEC within 60 days of each fund's fiscal quarter-end. Other disclosures of portfolio holdings may only be made when the Funds’ Chief Compliance Officer determines that the disclosures are for a legitimate business purpose (such as to service providers or broker-dealers in connection with the performance of services for the Funds) and that the recipient is made aware that the information provided is strictly confidential and that they may not trade in securities based on non-public information that may be included in the disclosures. The Trustees periodically review Fund portfolio holdings disclosures and their recipients as part of their overall review processes. Service providers that are currently authorized for disclosure of information are the Trust’s Adviser, Distributor, Transfer Agent, Custodian(s), Auditors, Accountants, Counsel and each of their respective affiliates and advisers. Any additional parties to whom portfolio holdings information is disclosed will be reported to the Board of Trustees. The Trust’s policies and procedures prohibit any person or entity from receiving compensation or consideration of any kind in connection with any disclosures of portfolio holdings. The Trust believes that the foregoing procedures substantially eliminate the likelihood of conflicts between the interests of shareholders and affiliates of the Trust.
Business Continuity Plan
Third Avenue Management (“TAM”) has developed a Business Continuity Plan (“BCP”) outlining the processes that will be implemented in response to events that significantly disrupt our business. The timing and impact of disasters and disruptions are unpredictable, so we will be flexible in responding to events as they occur. If you are not able to contact TAM as you normally would after a significant business disruption, please visit our website at www.thirdave.com for contact information. TAM plans to resume business operations as quickly as possible after a significant business disruption. TAM’s BCP includes, among other procedures, instructions regarding the following: safeguarding TAM employees and TAM property, protecting TAM’s books and records, and allowing our customers to transact business. TAM’s BCP addresses data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business. Significant business disruptions can vary in scope (i.e. only TAM, a single building housing TAM, the business district where TAM is located, etc.) The severity of disruptions can also vary from minimal to severe. The plan developed by TAM addresses all potential disruptions and we are confident that it will help us to resume business as soon as possible following a significant business disruption. If a disruption is so severe that it prevents TAM from remaining in business, we will assure our customer’s prompt access to their funds and securities.
Third Avenue email communication is for informational purposes only. It is not intended as an offer or solicitation for the purchase or sale of any financial instrument or as an official confirmation of any transaction. All market prices, data and other information are not warranted as to completeness or accuracy and are subject to change without notice. Any comments or statements made herein do not necessarily reflect the views of Third Avenue Management LLC, its subsidiaries and affiliates. This transmission may contain information that is privileged, confidential, legally privileged, and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. Although this transmission and any attachments are believed to be free of any defects that might affect any computer system into which it is received and opened, it is the responsibility of the recipient to ensure that it is free of defects and no responsibility is accepted by Third Avenue Management LLC, its subsidiaries and affiliates, as applicable, for any loss or damage arising in any way from its use. If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format.