Services ThePARTNERS Wealth Management ("ThePARTNERS" or the "Advisor") provides customized investment management and related advisory services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the ThePARTNERS Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting ThePARTNERS as your investment adviser. As part of the investment advisory fee noted in Item 5 of the Part 2A Disclosure Brochure, ThePARTNERS includes normal securities transaction fees and a platform fee as part of the overall investment advisory fee. Securities regulations often refer to this combined fee structure as a "Wrap Fee Program". The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosures relating to the combination of securities transaction fees and a platform fee into the single "bundled" investment advisory fee. Please see Item 4 - Advisory Services of the Part 2A Disclosure Brochure for details on ThePARTNERS' investment philosophy and related services. For information regarding this ADV Part 2A Disclosure Brochure, please contact Jeffrey Smith, Chief Compliance Officer at jeffsmith@thepartnerswm.com. Program Costs Advisory services provided by ThePARTNERS may be offered as a Wrap Fee Program whereby normal securities transaction costs are included in the overall investment advisory fee paid to ThePARTNERS. As the level of trading in a Client's account may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the transaction costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on the services to be provided to each Client, however, the Client is not charged more if there is higher trading activity in the Client's account. A Wrap Fee structure has a potential conflict of interest as the Advisor may have an incentive to limit the number of trades placed in Clients' accounts. Please note that certain broker-dealers have lower transaction fees than other broker-dealers and as a result overall separate fees may be lower now than in the past in relation to these particular broker-dealers and custodians. Please see Item 5 - Fees and Compensation of the Part 2A Disclosure Brochure for complete details on fees. You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included in the wrap-fee you are charged by our firm. As ThePARTNERS, the registered investment adviser (“RIA”) absorbs certain transaction costs in wrap fee accounts, the RIA may have a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists for the RIA to place trades less frequently in a wrap fee arrangement. We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. Fees Investment Advisory Services The Investment Adviser Representative ("IAR") will discuss the investment advisory fees when your account is established, and these fees will be outlined in the advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior billing period and are billed at an annual rate of up to 2.99%, depending on factors such as the level of assets being managed, the complexity of the services to be provided and/or the overall relationship with the Client. In addition to the investment advisory fee, the Client may also pay a platform fee of up to .25% annually. The platform fee is for securities transaction fees, reporting and related services. Fees are paid quarterly, in advance of each calendar quarter (the billing period), pursuant to the terms of the investment advisory agreement. Fees

for the first partial billing period of service are prorated from the inception date of the account[s] to the end of the first billing period. Fees may be negotiable at the sole discretion of the Adviser. Certain Clients may have a fixed annual fee or fixed rate fee or a fee schedule that differs from above. The Client's fees will take into consideration the aggregate assets under management with Adviser. All securities held in accounts managed by ThePARTNERS will be independently valued by the Custodian. ThePARTNERS will not have the authority or responsibility to value portfolio securities. Clients should review their advisory agreement for additional information relative to fees and fee billing. The Client may make additions or withdrawals from the account[s] at any time, subject to the ThePARTNERS' right to terminate an account or the overall relationship. Additions may be in cash or securities provided that the Advisor reserves the right to liquidate any transferred securities or decline to accept particular securities into a Client's account[s]. Clients may withdraw account assets on notice to ThePARTNERS, subject to the usual and customary securities settlement procedures. However, ThePARTNERS typically designs its investment portfolios as long-term investments, and the withdrawal of assets may impair the achievement of a Client's investment objectives. ThePARTNERS may consult the Client about the implications of such transactions. Clients are advised that when such securities are liquidated, they may be subject to securities transaction fees, short-term redemption fees, and/or tax ramifications. If assets in excess of $25,000 are deposited into or withdrawn from the Client's account[s], an adjustment will be made in the next billing period to reflect the fee difference. ThePARTNERS may negotiate a fee that differs from the schedule above for certain account[s] or holdings. As noted above, the Wrap Fee Program includes normal securities trading costs incurred in connection with the discretionary investment management services provided by ThePARTNERS. Securities transaction fees for Client-directed trades may be charged back to the Client. In addition, all fees paid to ThePARTNERS for investment advisory services are part of the Wrap Fee Program and are separate and distinct from the expenses charged by mutual funds and exchange- traded funds to their shareholders, if applicable. These fees and expenses are described in each fund's prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. The Client may also incur other costs assessed by the Custodian or other parties for account related activity fees, such as wire transfer fees, trade away fees and other fees. The Advisor does not control nor share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged by ThePARTNERS to fully understand the total fees to be paid. Please see Item 5.C. - Other Fees and Expenses in the Part 2A Disclosure Brochure provided separately. Compensation ThePARTNERS is the sponsor and portfolio manager of this Wrap Fee Program. ThePARTNERS receives an investment advisory fee paid by Clients for investment advisory services covered under this Wrap Fee Program. Fees and Costs Not Included Our wrap fee covers our advisory services and the brokerage services provided by Schwab, including custody of assets, equity trades, ETFs, and agency transactions in fixed income securities. As a result, we have an incentive to execute transactions for your account at Schwab. Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees (such as a commission or markup) for trades executed away from Schwab at another broker-dealer, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. This would be similar if assets were held at other custodians.