Investment Performance
The Board considered each Fund’s investment results in comparison to its stated investment objectives. The Trustees also reviewed performance rankings for each Fund as provided by an independent third-party service provider. In assessing performance of the Nasdaq-100 Index Fund, SmallCap Index Fund, S&P 500 Index Fund, and MidCap Index Fund, the Trustees took into consideration the fact that Fund performance is expected to mirror the appropriate benchmarks as closely as possible given certain practical constraints imposed by the 1940 Act, the Fund’s investment restrictions, the Fund’s size, and similar factors. The Trustees also considered supplemental peer category performance information provided by the Adviser. Among the factors considered in this regard, were the following for the periods ended December 31, 2022:
•For the Green California Tax-Free Income Fund, it was noted that the Fund was in the second highest performing quartile relative to its peer category over the 1-year period, the second to lowest quartile over the 3-year and 10-year periods and the lowest performing quartile over the 5-year period.
•For the Nasdaq-100 Index Fund, it was noted that the performance of the Fund was in the highest performing quartile relative to its peer category over the 3-year, 5-year and 10-year periods and in the second lowest performing quartile over the 1-year period.
•For the S&P 500 Index Fund, it was noted that the performance of the Fund relative to its peer category was in the second highest performing quartile over the 3-year, 5-year, and 10-year periods, and in the second lowest performing quartile over the 1-year period.
•For the S&P MidCap Index Fund, it was noted that the performance of the Fund relative to its peer category was in the second highest performing quartile over the 1-year, 3-year and 10-year periods, and the second lowest performing quartile for the 5-year period.
•For the S&P SmallCap Index Fund, it was noted that the performance of the Fund relative to its peer category was in the highest performing quartile over the 10-year period, in the second highest performing quartile over the 3-year and 5-year periods, and in the second lowest performing quartile over the 1-year period.
•For the Shelton Sustainable Equity Fund, it was noted that the performance of the Fund relative to its peer category was in the highest performing quartile over the 3-year and 5-year periods and in the second highest performing quartile over the 1-year period.
•For the Shelton Equity Income Fund, it was noted that the performance of the Fund relative to its peer category was in the highest performing quartile over the 10-year period and in the second highest performing quartile over the 1-year, 3-year, and 5-year periods.
•For The United States Treasury Trust, it was noted that the Fund’s total return performance, while small, was positive during the one-year period ended December 31, 2022.
•For the U.S. Government Securities Fund, it was noted that the performance of the Fund relative to its peer category was in the highest performing quartile over the 1-year and 3-year periods, the second highest performing quartile over the 5-year period, and the second lowest performing quartile over the 10-year period.
The Board ultimately concluded that SCM’s performance records in managing the Funds was satisfactory, and in some cases excellent, supporting the determination that SCM’s continued management under the Shelton Funds Advisory Agreement would be consistent with the best interests of each Fund and its shareholders.
Management Fees and Total Annual Operating Expense Ratios
The Board reviewed the management fees and total operating expenses of each Fund and compared such amounts with the management fees and total operating expenses of other funds in the industry that are found within the same style category as defined by a third-party independent service provider. The Board considered the asset size, advisory fees and total fees and expenses of each Fund in comparison to the asset size, advisory fees and other fees and expenses of other funds in each Fund’s relevant category. The Trustees considered both the gross advisory fee rates, as well as the effective advisory rates charged by Shelton Capital after taking into consideration the expense limitation arrangements on certain Funds.
The Board noted that except for the U.S. Government Securities Fund, the Green California Tax-Free Income Fund, and The United States Treasury Trust which were higher than their respective peer category medians, and the Shelton Sustainable Equity Fund which was equal to its peer category median, the maximum management fee charged to each Fund was generally lower than the Funds’ respective peer category medians.
The Board also observed that each Fund’s total annual operating expense ratios, after taking into account the expense limitations and waivers applicable to certain Funds, were generally higher than the category median for other comparable funds, with the exception of the Institutional Classes of the Nasdaq-100 Fund and the Shelton Sustainable Equity Fund, the Investor Classes of the US Government Securities Fund, Shelton Equity Income Fund, Nasdaq-100 Fund, Small Cap Index Fund, MidCap Index Fund, and the S&P 500 Index Fund, and Class K of the S&P 500 Fund, which were below their respective category medians for comparable funds.
Comparable Accounts
The Board noted certain information provided by Shelton Capital regarding fees charged to other clients utilizing a strategy similar to that employed by an applicable Fund. The Board determined that, bearing in mind the limitations of comparing different types of managed accounts and the different levels of service typically associated with such accounts, the fee structures applicable to Shelton Capital’s other clients employing a comparable strategy to each Fund was not indicative of any unreasonableness with respect to the advisory fee payable by such Fund.
Cost Structure, Level of Profits, Economies of Scale and Ancillary Benefits
The Board reviewed information regarding Shelton Capital’s costs of providing services to the applicable Funds. The Board also reviewed the resulting level of profits to Shelton Capital, including the cost allocation methodologies used to calculate such profits. The Independent Trustees received financial and other information from Shelton Capital.
The Board noted its intention to continue to monitor assets under management, and the resulting impact on Shelton Capital’s profitability, in order to ensure that it has sufficient resources to continue to provide the services that shareholders in the Funds require. They further considered that breakpoints in the advisory fee structure of certain Funds provide for reductions in the level of fees charged by Shelton Capital to such Fund as Fund assets increase, reflecting the fact that economies of scale in the cost of operations will be shared with such Fund’s shareholders. The Trustees also noted that currently, Shelton Capital has contractually agreed to limit its advisory fees on certain Funds so that those Funds do not exceed their respective specified operating expense limitations and may extent those limits in the future.
The Board also considered that Shelton Capital does not receive material indirect benefits from managing the Funds, noting the soft dollars benefits accrued to Shelton Capital.
Based on the foregoing, together with the other information provided to it at the Meeting and throughout the year, the Board concluded that each applicable Fund’s cost structure and level of profits for Shelton Capital were reasonable and that economies of scale and ancillary benefits, to the extent present with respect to a Fund, were not material.