Advisory Services Offered Phil D. Wheat and Lori Givens co-own Wheat-Givens Financial, LLC (“WGF” or “the Firm”), which began doing business in 1996 (formerly known as Phil D. Wheat, CFP®) in McKinney, TX. WGF offers client the choice of discretionary or non-discretionary asset management services combined with financial planning through the Wheat-Givens Financial, LLC Wrap Fee Program (hereinafter referred to as the “Program”), where it serves as the Program’s sponsor and sole Portfolio Manager. WGF offers Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment program will be based on the above factors. Discretionary When the Client elects to use WGF on a discretionary basis, the Client will sign an Advisory Services Agreement granting limited trading authorization, which allows WGF to determine the securities to be bought or sold and the amount of the securities to be bought or sold. WGF will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-Discretionary When the Client elects to use WGF on a non-discretionary basis, WGF will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, WGF will obtain prior Client approval on each and every transaction before executing any transaction. WGF Wrap Program fees include Financial Planning and consulting services for clients in the following areas:
• pre-retirement and post-retirement financial consulting
• customized investment allocation plans
• investment and estate planning
• corporate retirement plans
• advisory services
• business continuation and executive/owner benefit planning
• educational and special needs funding strategies Clients are provided with a written comprehensive financial plan that is presented to illustrate their current financial situation and objectives and to provide specific recommendations of how their goals can best be attained. The plan will include as many of the areas above as the client wishes. WGF charges a quarterly investment advisory fee based on your assets under management. Fees per household will not exceed the following maximums: 0.25% per calendar quarter (1.00% annualized) up to and including $500,000 0.125% per calendar quarter (0.50% annualized) for amounts in the household accounts above $500,001 *No fees will be charged for short-term assets (money market funds, CDs) held in accounts. This is a blended fee schedule, meaning different asset levels are assessed different fees, then combined for a total investment fee. WGF Wrap Program fees are computed and payable quarterly in advance during the first month of each calendar quarter and will be calculated based on the market value of the client account assets held on the last day of the prior quarter. Fees shall be deducted from the client’s Wrap Fee Account on a quarterly basis unless otherwise instructed by the client. If there are insufficient money market funds available at the time fees are due, WGF will withdraw the amount(s) due once those funds become available through client-authorized transactions. This may result in multiple fee billings within the same billing period. No late fees will be charged on past-due fees. WGF, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). For all services, Clients may terminate their engagement with WGF within five (5) business days of signing an Agreement with no obligation and without penalty. After the initial (5) business days, the Agreement may be terminated by WGF with thirty (30) days written notice to Client and by the Client at any time with written notice to WGF. If the account is terminated prior to the end of a quarter, the fee for that quarter will be prorated for the number of days the account was open during that quarter, and any overpayment will be returned to the client following the closing of the account. Fee Comparison Clients may be able to

purchase services similar to those offered under the Program from other service providers either separately or as part of a similar wrap fee program. These services or programs may cost more or less than our Program, depending on the fees charged by such other service providers. For example, the Program Fee, which is fixed regardless of the number of transactions occurring in the account, may be more or less than paying for execution on a per-transaction basis.
• The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account.
• For example, a wrap fee program may not be suitable for all accounts, including but not limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other transaction fees. WGF does not include cash or cash-equivalent balances when calculating fees to eliminate this conflict.
• In order to evaluate whether a wrap [or bundled] fee arrangement is appropriate for you, you should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program. Conflict of Interest. When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services, the balance of the total wrap [or program] fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee.
• For example, our wrap fee arrangement creates incentives for our firm to trade less frequently or select investments that reduce our costs, and in some cases increase expenses that are borne by the client. Additionally, an increasing number of custodians generally do not charge commissions [or transaction fees] for online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these types of securities, we can do so without paying commissions to the account custodian. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. Additional Fees WGF pays all custodian fees and transaction fees for all accounts under this Program. However, custodians may charge other related costs on the purchases or sales of mutual funds, equities, bonds, options, margin interest, and mark-ups, markdowns, or spreads paid to market makers. Mutual funds, money market funds, and exchange-traded funds may also charge internal management fees, which are disclosed in the fund’s prospectus. WGF does not directly receive any compensation from these fees. The Firm selects mutual funds by criteria, such as past total return performance as well as risk, diversification, internal fund fees, price to earnings ratios, and volatility measures. Broker compensation is not a selection criteria because we do not use “sales charge” funds. If a fund has a sales charge, we will not recommend it unless the fund company will waive the sales charge in an Advisory Service account. Some funds have what is known as a 12b-1 charge as a part of their annual fee structure. This is normally in the 0.25% range. Some part of 12b-1 fees comes to the broker as compensation. If the fund family offers the same fund without 12b-1 fees, we either recommend the non-12b-1 version fund, or if the version without the 12b-1 fees has become available after its counterpart was already in place in an account, we subtract the 12b-1 fees from client fees on a quarterly basis. Additional Compensation WGF nor its employees receive compensation, other than the portfolio management fee, for the recommendation to the Client or the Client’s participation in the Program.