A. Description of the Advisory Firm Northfront Financial USA Inc (hereinafter “NFUI”) provides portfolio management to clients under this wrap fee program as sponsor and portfolio manager. Total Assets Under Management Annual Fees $0 - $500,000 2.50% $500,001 - $1,000,000 1.75% $1,000,001 - $3,000,000 1.50% $3,000,001 - $5,000,000 1.25% $5,000,001 – And Up 1.00% Portfolio management fees are withdrawn directly from the client’s accounts with client’s written authorization on a quarterly basis. Fees are paid in arrears. Fees are paid in arrears on a quarterly basis. The advisory fee is calculated using the value of the assets on the last business day of the prior billing period. For all asset-based fee, the fee collected will be the daily rate * times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty, for full refund of NFUI’s fees, within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. B. Contribution Cost Factors The program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if

provided separately (which in turn depends on the prices and specific services offered by different providers). C. Additional Fees NFUI will wrap third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.) for wrap fee portfolio management accounts. NFUI will charge clients one fee, and pay all transaction fees using the fee collected from the client. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that NFUI has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or broker-dealers, 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. D. Compensation of Client Participation Neither NFUI, nor any representatives of NFUI receive any additional compensation beyond advisory fees for the participation of client’s in the wrap fee program. However, compensation received may be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, NFUI may have a financial incentive to recommend the wrap fee program to clients.