Description of Services The Simmons Capital Group Wrap Program (the Program) is an investment advisory program sponsored by Simmons Capital Group (Simmons Capital). The Program provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. To join the Program a person must: 1) Provide information about their financial needs, investment objectives, time horizon, and risk tolerance, as well as any other factors relevant to their specific financial situation and any other supporting documentation required for the Program; 2) Complete a new account agreement with the broker dealer approved by Simmons Capital for participation in the Program (Broker-Dealer); and 3) Open a securities brokerage account with the Broker-Dealer (an Account) and deposit those client assets designated for participation in the Program (Program Assets) into the Account. After an analysis of any information provided by the client to Simmons Capital, Simmons Capital shall assist the client in developing an appropriate investment strategy for the Program Assets in their Account(s) (the Investment Strategy). Thereafter, all clients are encouraged to discuss their needs, goals, and objectives with Simmons Capital and to keep the Simmons Capital informed of any changes thereto. Simmons Capital shall contact clients at least annually to review its previous services and/or recommendations and to determine whether changes should be made to their Investment Strategy. Management of Your Portfolio All clients in the Program shall grant Simmons Capital discretionary authority to buy, sell, and otherwise trade in the type of securities described in Item 6 (below) for their Account(s) and to liquidate previously- purchased securities that the client has transferred to their Account(s). Program Assets in the client’s Account(s) shall be managed by one of Simmons Capital’ investment adviser representatives. The Program may recommend that clients authorize the active discretionary management of certain Program Assets by and/or among one or more independent investment managers (Independent Managers) to implement a particular Investment Strategy. The terms and conditions under which the client shall engage the Independent Manager(s) may be set forth in separate written agreements between (1) the client and Simmons Capital and (2) Simmons Capital or client and the designated Independent Manager(s). Simmons Capital shall continue to render advisory services to the client relative to the ongoing monitoring and review of account performance, for which Simmons Capital shall receive an annual advisory fee which is based upon a percentage of the market value of the Program Assets being managed by the designated Independent Manager(s). Factors that the Registrant shall consider in recommending Independent Manager(s) include the client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. In addition to Simmons Capital’ written disclosure statement, the client shall also receive the written disclosure statement of the designated Independent Manager(s). Neither Simmons Capital nor the client may assign the Program Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of Simmons Capital shall not be considered an assignment. Fees for Participation in the Program Clients in the Program pay a single annualized fee for participation in the Program (the Program Fee). Simmons Capital shall charge an annual fee based upon a percentage of the market value of the assets being managed by Simmons

Capital. Simmons Capital’s annual fee shall be prorated and charged quarterly, in arrears, based upon average daily balance of the assets being managed by Simmons Capital. The annual fee shall vary (between 0.85% and 1.50%) depending upon the market value of the assets under management. A separate fee arrangement may be established depending on the independent manager selected. Simmons Capital, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre- existing client, account retention, pro bono activities, etc.). Under the Program, clients receive investment advisory services, custody and execution of transactions in securities for a single, combined annualized fee, the Program Fee. Participation in the Program may cost the client more or less than purchasing such services separately. The number of transactions made in the client’s Account(s), as well as the commissions charged for each transaction, will determine the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. The Program Fee may be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Clients may incur certain charges imposed by third parties in addition to the Program Fee such as fees charged by Independent Managers, charges imposed directly by a mutual fund or exchange traded fund in the account, which shall be disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), charges imposed by private funds (to the extent the applicable Program Account is qualified and has elected to include such assets in its portfolio, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Co-Managed Accounts For accounts co-managed with Steward Advisors Group, LLC (“Steward”), the Program Fee may be directly debited from the applicable account(s), either by Simmons Capital or Steward. The Program Fee will be shared among Simmons Capital or Steward as set forth in a Co- Management Agreement between Simmons Capital and Steward. Simmons Capital will not receive any fees with respect to co-managed accounts, other than a share of the Program Fee payable to Steward. Fees for Management During Partial Quarters of Service For the initial period of participation in the Program, the Program Fee shall be calculated on a pro rata basis. The Program Agreement between Simmons Capital and the client will continue in effect until terminated by either party pursuant to the terms of the Program Agreement. The Program Fee shall be prorated through the date of termination and any remaining balance shall be refunded to the client in a timely manner. Additions may be in cash or securities provided that Simmons Capital reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Simmons Capital may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. If assets are deposited into or withdrawn from an account after the inception of a quarter, the Program Fee with respect to such assets will be prorated based on the number of days remaining in the quarter.