The IWM Wrap Fee Program (the “Program”) is an investment advisory program sponsored by IWM. 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 client must: 1) Complete an investor profile that describes the client’s financial needs, investment objectives, time horizon, and risk tolerance, as well as any other factors relevant to the client’s specific financial situation and any other supporting documentation the Program requires; 2) Complete the investment advisory wrap fee agreement (the “Agreement”) with IWM; 3) Complete a new account agreement with a custodian broker-dealer IWM approves for participation in the Program (“Financial Institution”); and 4) Open a securities brokerage account with the Financial Institution and deposit those assets designated for participation in the Program into the account. After an analysis of any information provided by the client to IWM, IWM assists the client in developing an appropriate investment strategy for the assets in their accounts. Thereafter, all clients are encouraged to discuss their needs, goals, and objectives with IWM and to keep IWM informed of any changes thereto. IWM contacts ongoing 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 grant IWM discretionary authority to buy, sell, and otherwise trade in the type of securities described in Item 6, below for their accounts and to liquidate previously- purchased securities that the client has transferred to their Accounts. Assets are managed by IWM’s principal owner, Chris Holden. Fees for the Program Clients in the Program pay a single annualized fee for participation in the Program (the “Program Fee”). The Program Fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by IWM under Program on the last day of the previous quarter. The Program Fee varies pending upon the market value of the assets under management, as follows: PORTFOLIO VALUE BASE FEE up to $750,000 1.15% Next $750,000 0.95% Next $1,000,000 0.75% Next $2,500,000 0.65% above $5,000,000 0.45% IWM, in its sole discretion, may negotiate to charge a lesser Program Fee based upon certain criteria (i.e., related

accounts, anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, account composition, pre-existing client, account retention, pro bono activities, etc.). Fee Comparison As referenced above, a portion of the fees paid to IWM are used to cover certain securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Because the firm pays for the brokerage fees, the firm has an incentive to engage in less transactions, or transactions that cost less to the firm, including the use of mutual funds that do not have transaction charges, but have higher expenses to the client. The firm reviews the frequency and type of investments made in client accounts to act in the client’s best interest. Other Charges In addition to the advisory fees paid to IWM, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively, “Financial Institutions”). These additional charges may include margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund Program Fees and other fund expenses), fees and commission for assets not held with the Financial Institutions offered in the Program such as 401(k) or 529 plan assets as well as for fees for trades executed away from that Financial Institution (a conflict of interest exists where the firm avoids expenses by trading through a different Financial Institution), mark-ups and mark-downs on fixed-income transactions which cannot be paid by the firm (or it is overly burdensome to determine the amount of such mark-ups / downs), 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.