A. Description of the Advisory Firm Candor Financial LLC (hereinafter “Candor”) provides advisory services to clients under this wrap fee program as sponsor and portfolio manager. Candor’s primary service offering is the management of a trading plans under SEC Rule 10b5-1 and associated portfolio management. Candor provides its services through the internet via an online interface (a “robo-advisor”), providing automated advisory services solely online without a particular advisor with whom the client interacts with. The firm is based in San Francisco, CA. Fees Candor offers two services, each with a separate fee:
• Establishment of a trading plan pursuant to Rule 10b5-1, for which clients pay a flat fee of $250/year
• Portfolio management for proceeds of the trading plan, for which clients pay an annual advisory fee of 0.75% of assets under management (AUM) Candor’s fees are negotiable and we may offer promotions from time to time, including waivers, reductions and discounts of the standard fee. Candor requires clients use Apex Clearing as custodian. Candor’s fees are debited from the client's account at the custodian. Fees are paid monthly in arrears. Clients may terminate the agreement without penalty, for full refund of Candor’s fees, within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract upon two business days written notice. Portion of fees paid to portfolio managers Portfolio managers are not paid a portion of fees. 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 Candor will wrap commission/brokerage fees for wrap fee portfolio management accounts. Candor will charge clients one fee and pay the commission/brokerage 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 Candor 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, mark-ups and mark-downs, spreads paid to market makers, 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. Clients will receive a “Miscellaneous Term Sheet” at account opening that provides additional detail for third party fees. These fees are not included within the wrap fee you are charged by our firm. We receive no compensation of any kind for these additional expenses. D. Compensation of Client Participation Neither Candor, nor any representatives of Candor 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, Candor has a financial incentive to recommend the wrap fee program to clients.