Description of Business D.H. Hill Advisors, Inc. (“D.H. Hill”) is a Texas state registered investment advisor firm. D.H. Hill is a corporation that was established in the state of Texas in 1998, founded by Dan Hill with the principal office located in Kingwood, Texas. D.H. Hill independent representatives are located in geographically separated offices and operate through various business names or other corporate structures held out to the public for marketing purposes, for which wealth and investment management services are provided through D.H. Hill. D.H. Hill does not have any ownership interest in the representative’s trade name or other corporate structure. General Description of the D.H. Hill Wrap Program The D.H. Hill Connect and Select Wrap Programs, (Program) are an investment advisory Program sponsored by D.H. Hill. The Program allows D.H. Hill and IAR to manage Client accounts for a single fee that include portfolio management services and brokerage costs. Program uses a variety of asset classes and investment vehicles that typically include mutual funds, exchange traded funds (“ETFs”), equity securities, fixed income securities, other related securities, and sub-managers. Client accounts are generally invested in strategies, with similar accounts invested in the same securities. Accounts are also managed at a custom level, with security selection varying from one Client to another. D.H. Hill IARs work with Clients to understand the Client’s risk tolerance, investment objectives, and investment attribute preferences and to determine an appropriate asset portfolio construction. D.H. Hill IARs determine an appropriate portfolio for each of their clients.  D.H. Hill Connect Program (“Connect”) – Charles Schwab/ Fidelity D.H. Hill sponsors and oversees the IAR as portfolio manager for Connect, where D.H. Hill offers clients the opportunity to hire IAR to manage designated accounts on a discretionary basis including constructing portfolio models based on client stated risk and objectives. Investment offerings within Connect can include, but are not limited to, stocks, ETFs, mutual funds, individual bonds, CDs, and derivatives.  D.H. Hill Select Wrap Program (“Select”) – Charles Schwab D.H. Hill sponsors and acts as the overlay portfolio manager for Select, where D.H. Hill offers clients the opportunity to hire D.H. Hill Investment Committee to manage designated accounts on a discretionary basis including constructing portfolio models based on client stated risk and objectives. Investment offerings within Select are limited to ETFs, mutual funds, and sub-managers. IARs can recommend one or more of the Select portfolio models. The IAR has no trading authorization. Financial Professional A Financial Professional is the person(s) who introduces the Client to this Program and/or the person(s) providing investment advisory services to the Client in this Program. Financial Professional may include: Investment Advisor Representative (“IAR”) of D.H. Hill; an IAR not affiliated with D.H. Hill; or a solicitor of D.H. Hill. To select the appropriate investment strategy for the client when the Financial Professional is a Solicitor of D.H. Hill: D.H. Hill will assess Clients’ personal situation, risk profile and/or other methods to determine the best investment model to meet investment objectives. When Clients Financial Professional is an Investment Advisor Representative of D.H. Hill or an IAR not affiliated with D.H. Hill: To select the appropriate investment strategy for client, the IAR will assess clients’ personal situation, risk profile and/or other methods to determine the best investment model to meet investment objectives. Cost of Services Prior to engaging D.H. Hill Advisory Services, clients are required to enter into one or more agreements with D.H. Hill and the IAR setting terms and conditions of the engagement including, but not limited to: describing the scope of services to be provided, termination, confidentiality, disclosures, and client fees (collectively the “Client Agreement”). The annual cost is negotiated with each Client and is customized depending on several factors as discussed in the “Negotiated Costs” section below. The following Cost of Services schedules provide information about how D.H. Hill charges for its Wrap Program. D.H. HILL CONNECT COST OF SERVICES SCHEDULE (Annual) Client Assets Under Management Financial Professional Fee Connect Program Fee Asset Based Pricing Fee $0 - $2,000,000 1.25% 0.25% 0.10% - 0.25% $2,000,000 - $5,000,000 1.00% 0.22% 0.10% - 0.25% $5,000,000 - $10,000,000 0.85% 0.18% 0.10% - 0.25% Greater than $10,000,000 Negotiable 0.15% minimum 0.10% - 0.25% D.H. HILL SELECT COST OF SERVICES SCHEDULE (Annual) Client Assets Under Management Financial Professional Fee Select Program Fee Asset Based Pricing Fee $0 - $2,000,000 1.00% 0.55% 0.10% $2,000,000 - $5,000,000 0.85% 0.50% 0.10% $5,000,000 - $10,000,000 0.75% 0.45% 0.10% Greater than $10,000,000 Negotiable 0.40% minimum 0.10% Certain custodians charge a minimum annual Asset Based Pricing Fee (“ABP”) which could make the annual ABP fee higher than the stated percentage of assets under management fee. The D.H. Hill Select Cost of Services Schedule does not typically include costs charged by certain managers, Sub-Managers in the D.H. Hill Select Program. These annual costs range from 0% to1% of the Client’s assets under management. The Client’s total Cost of Services is a flat rate and not blended. The Total Fee charged as a percentage of assets under management to a Client Account will not exceed 3.00% of the value of the portfolio annually. Negotiated Costs The amount and method for calculating D.H. Hill Investment Management costs as referenced in the Cost of Services schedule are negotiated with each Client and confirmed in the Client Agreement, or if the schedule has changed since the initial Client Agreement the Client signed, then through supporting documentation. While the Investment Management costs are typically assessed as a percentage of the Client’s assets under D.H. Hill’s management, it may also be assessed as a flat dollar amount. The Client is subject to the fee rate that is agreed to in their Client Agreement, which may be higher or lower than the fee schedule noted above. D.H. Hill considers a number of variables when analyzing the specific services to be provided to the Client and when determining the appropriate cost for those services. Factors that determine the Cost of Services include, but are not limited to:  the services expected to be performed  the Client’s wealth counseling and investment needs  the amount of investable assets  the Client’s net worth  the amount of time anticipated to be spent servicing the Client  local regional office precedence based on historical costs charged to other similar Clients The Client’s IAR will determine the Cost of Service after carefully balancing the consultative and the implemented portions of the Client relationship. As a result, similar Clients may be charged different costs for similar services and the actual Cost of Services may be higher than the rates noted in the above schedule. The Client’s IAR reserves the right to determine whether Client accounts are "related" for purposes of aggregation. A determination of the related accounts is part of the Cost of Services negotiation between the Client and IAR. The Client should be aware that there may be certain restrictions on the aggregation of investments for ERISA, trusts, and IRA Client accounts. In those instances where the majority of a Client’s account is invested in fixed income securities, the Client’s IAR reserves the right to offer a reduced Cost of Services. For accounts where D.H. Hill is the investment adviser exercising discretion, the Cost of Services schedule is typically applicable to all assets under management, including cash and cash equivalents. The actual Cost of Services negotiated with the Client may determine that cash and/or cash equivalents are not to be included in the total Cost of Services. When cash and cash equivalents are not included, this creates a conflict of interest as D.H. Hill earns more fees when those assets are invested in securities it acquires. This conflict can be addressed by the Client and IAR pre-determining the amount of cash that will not be included with billing, or a pre- determination by the Client and IAR that a specific cash amount will be not be subject to D.H. Hill’s advisory services, or by billing on all assets under management. Investment Management Costs D.H. Hill charges its Clients an annual management Cost of Services based on an agreed upon percentage of the Client’s assets under management. These investment management costs are payable monthly or quarterly. The method for billing these costs may vary based custodian, local regional offices, or IARs, historical method and is agreed upon under the terms of the Client Agreement or supporting documentation if there were changes made after the Client signed the Client Agreement. D.H. Hill typically bills its investment management

costs in advanced based on the value of the assets in the Client’s account at the end of the previous month or quarter (based on service provider selected). In certain situations, as agreed upon in the agreement, D.H. Hill may bill costs in arrears, based on average daily balance of the account during the prior month or quarter, rather than in advance, or other methods. For new accounts and for new assets added after the start of a month or quarter, accounts will either be billed when the assets are available to be managed by D.H. Hill, or in arrears, after the end of the month or quarter account was funded (based on service provider selected). D.H. Hill’s annual investment management Cost of Services includes costs for the following services: review, selection, monitoring, and replacement services for a variety of securities, including but not limited to exchange traded funds, exchange traded notes, mutual funds, individual securities, bonds and sub-managers, and related services. D.H. Hill relies on a number of different resources to price securities held in Client accounts, including multiple portfolio accounting systems (primarily Orion and Trust Company of America), pricing services and custodians. As a result, Clients may receive different statements displaying a different valuation of the same security, based on the source of the data. Additionally, different Clients with the same security may pay different costs depending on the valuation source of the securities in their specific account. There are certain costs that Clients may incur, which are not included as part of the annual Cost of Services for Investment Management services charged by D.H. Hill. D.H. Hill may have an incentive to recommend its own strategies that have a manager cost associated rather than a non- affiliated manager, or into a strategy without additional costs, since it gets paid more when recommending its own strategies that have a supplemental cost. The amount that D.H. Hill is paid when Clients invest in its strategies is based on an estimate of costs, which include third party research, third-party manager expense, reporting fees, and strategy implementation and trading costs. The supplemental cost charged for investing in certain investment strategies does not include custody fees, as described in the next paragraph. In addition to, and separate from, D.H. Hill’s Cost of Services and supplemental investment manager costs, Clients may be charged the following costs from their account custodian: national securities exchange costs, charges for transactions with respect to assets not executed through the custodian; short term redemption costs; costs charged to shareholders of mutual funds and exchange traded funds by the fund manager; odd-lot differentials; American Depository Receipt costs; costs associated with exchanging currencies; or other costs required by law. Administrative costs for retirement accounts and any platform (technology) costs are paid directly by the Client, unless other arrangements have been made. Additionally, the Client will be charged for non-standard service costs incurred as a result of any special requests made by the Client, such as overnight courier or wiring costs. Generally, D.H. Hill does not have a minimum account size. In the case of sub-managed assets, a sub-manager may impose their own minimum account requirements. Any exceptions to account minimums are considered accepted once the management of Client assets begins. Upon giving notice to D.H. Hill, or by contacting their account custodian directly, Clients may make additions to, or withdrawals from their investment management accounts. Sub-Manager reserves the right to terminate any account falling below its stated account minimum. Account minimums are imposed for various reasons, including, but not limited to the diminishing impact on the smaller allocations within a broadly diversified portfolio, the impact on a smaller portfolios’ performance from transaction costs, the impact of a smaller portfolios’ transaction costs on the total expense to manage the portfolio, limitations on securities that may be purchased for smaller dollar amounts, amongst other reasons. D.H. Hill’s responsibility for advising Client accounts begins at the earlier of the “Effective Date” agreed to in the Client Agreement, or the date when the Client’s assets (cash and/or securities) have been credited to the Client’s account at the custodian and sub-custodian, if applicable. However, in no event shall costs begin accruing prior to the date the Client signs the Client Agreement. Where provided in its Client Agreements, and upon written notice, D.H. Hill reserves the right to amend its Cost of Services schedules at any time. Clients should be aware that the costs charged by D.H. Hill may be higher or lower than those charged by others in the industry and that it may be possible to obtain the same or similar services from other advisers at lower or higher rates. Clients should also be aware that Investment Professionals (“IPs” or Solicitors) not affiliated with D.H. Hill recommending these advisory services may receive compensation as a result of Clients’ contracting with D.H. Hill for such services. The IP recommending services may, therefore, have a financial incentive to recommend that a Client use D.H. Hill’s services over the services offered by other investment advisers. Investment Management Fee Payment For payment to D.H. Hill for its investment management services, D.H. Hill service providers send the custodian an invoice for monthly or quarterly cost debits. Clients will receive a monthly or quarterly statement from the custodian showing the amount of management costs that have been debited from their account. By signing the D.H. Hill Client Agreement, Clients are authorizing the debit of both the initial prorate fee and on-going monthly or quarterly costs. Mutual Fund and ETF Cost If mutual funds are selected for inclusion in Client accounts D.H. Hill manages, those mutual funds are either no-load funds or load-waived mutual funds. At times, mutual fund with a sales load may be transferred to D.H. Hill as part of new assets included under D.H. Hill’s management. When this is the case, it is D.H. Hill’s position that the mutual funds should be sold as soon as practicable. All mutual funds and ETFs pay management costs to their investment advisers, and certain funds and money-market accounts have other types of costs or charges, including 12b-1, administrative or shareholder servicing costs, early redemption, bank servicing or certain other costs, which may be deducted from the net asset value of the funds that may be held in Client accounts on a continuing basis. These costs are routinely charged to all fund or security shareholders or owners and are separate from and in addition to D.H. Hill’s management Cost of Services. Other Costs For custodial services, D.H. Hill utilizes the services of a number of firms to meet its Clients’ needs. Custodial transaction costs (for transactions executed through the custodian’s broker- dealer) may be paid by the Client or by D.H. Hill as negotiated and stated in the D.H. Hill Client Agreement. Custodians charge Clients other fees, beyond transaction costs. The additional costs charged to Clients by the custodian may include, but are not limited to, custodial and clearing agent services for Client accounts, maintenance of portfolio accounting systems, preparation and mailing of Client statements, account processing, systematic withdrawals, redemptions, retirement account custodial services (except for the retirement account termination cost), maintenance of a Client inquiry system, as well as execution of securities transactions in the Client’s account. Additionally, a transaction cost is charged by the Securities and Exchange Commission (SEC) to sellers of securities that are traded on stock exchanges and subsequently assessed to Clients. These costs are from Section 31(b) of the Securities Exchange Act of 1934 and are charged to recover the costs associated with the government’s supervision and regulation of the securities markets and securities professionals. Refer to ITEM 12: Brokerage Practices. Separate from costs assessed by the custodian, some Clients of D.H. Hill receive reports that display additional detailed performance information on their account(s). Such reports are provided to offer Clients additional insight about the way their accounts are performing and are provided in addition to the reports provided Clients through their account custodian. Notwithstanding, the performance information provided through reports, Clients should rely on the custodian statements for the most accurate account information. To produce these performance reports, D.H. Hill may charge Clients. The cost covers the reporting system expense and D.H. Hill associated administration of the system. The payment of this Reporting Cost may be made paid by D.H. Hill or by the Client, as negotiated. Certain states require service providers to pay a Gross Receipt Tax (GRT) for services provided to residents of the state, including New Mexico. When D.H. Hill is required to pay a GRT, it directly passes through such costs to Clients for whom it applies.