The RPATA Wrap Fee Program (the “Program”) is an investment advisory program sponsored by RPATA, a registered investment adviser which has been in business since September 2016 and is jointly owned by Revolution Partners, LLC of Memphis, Tennessee and ATA Advisory, LLC (“ATA”) of Union City, Tennessee. The Firm generally requests discretionary authority, including discretion to retain professional money managers. RPATA works with clients on comprehensively evaluating their investment portfolios using technology that enables the Firm to aggregate assets at other custodians, broker dealers, etc. RPATA seeks to leverage current research and build systems to support goals-based wealth management. The Firm works closely with clients to determine appropriate allocations within client portfolios. Based on the principle of diversification, the Firm may utilize professional money managers to manage investments within the various allocations. Alternately, the Firm may utilize investments selected by the Investment Committee of RPATA in accordance with the Firm’s policies and procedures. All investments selected follow the same allocation methodology whether or not outside money managers are utilized. RPATA then tracks the investments daily, provides periodic reviews to show progress towards specific goals and discusses adjustments as needed with the client. RPATA offers a variety of advisory services, which include financial planning, pension consulting and investment management services. Prior to the rendering of any advisory services, clients are required to enter into one or more written agreements with RPATA setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). RPATA is organized to provide investment management services specifically to clients of ATA. ATA is a joint owner of RPATA and thereby receives a monetary benefit, including a share of the revenues and profits/losses from its interest in RPATA. Employees of ATA do not receive direct payment for any referral. Clients of RPATA have been made aware of this structure. Clients of ATA are under no obligation to select RPATA for any services. Clients of RPATA also acknowledge as part of their Agreement that Revolution Partners, LLC and ATA share personal and financial data in the course of business. This data sharing is related to the tax planning, financial planning and investment selection services provided to the clients and is included in the fees charged for the advisory relationship. This Brochure describes the business of RPATA as it relates to clients receiving services through the Program. Certain sections also describe the activities of the Firm’s Supervised Persons, which refer to any officers, partners, directors (or other person occupying a similar status or performing similar functions), employees, or other persons who provide investment advice on RPATA’s behalf and are subject to the Firm’s supervision. Currently, all RPATA officers and employees are also and primarily officers and employees of Revolution Partners, LLC. In addition to the Program, the Firm may also offer financial planning, pension consulting and investment management services under different arrangements than those described herein. Information about these services is contained in RPATA’s Disclosure Brochure, which appears as Part 2A of the Firm’s Form ADV. RPATA is prohibited from serving organizations who are attest (audit) clients of ATA. Description of the Program The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered to be any arrangement under which clients receive investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions for a specified fee or fees not based upon transactions in their accounts. Prior to receiving services through the Program, clients are required to enter into an Agreement. Clients must also open a new securities brokerage account and complete a new account agreement with Schwab Advisor ServicesTM (“Schwab”) or another broker-dealer RPATA approves under the Program (collectively “Financial Institutions”). At the onset of the Program, clients complete an investor profile and participate in detailed conversations describing their individual investment objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors pertinent to their specific financial situations. After an analysis of the relevant information, including a foundational financial plan designed to address the client’s lifestyle expectations in retirement, RPATA assists its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are generally managed on a discretionary basis by either RPATA’s investment adviser representatives or an independent investment manager (collectively “Independent Managers”), as selected by RPATA. RPATA and/or the Independent Managers generally allocate clients’ assets among the various investment products available under the Program, as described further in Item 6 (below). Fees for Participation in the Program Investment management services are offered through the Program on a fee basis, meaning that clients pay a single annualized fee based upon assets under management. The Firm also offers advisory services outside of the Program under different fee arrangements (e.g., Standalone Financial Planning services). Investment Management Fees RPATA provides investment management services for an annual fee based on the amount of assets under the Firm’s management. Fees decrease at specific intervals as asset levels increase to provide value to the client. To offer clients full advantage of the lower fees available at higher asset tiers, all accounts in a household including Aggregated Assets are considered for billing. The Firm will only bill on selected Aggregated Assets which have been defined in a separate billing schedule. The entire value of all aggregated, whether billed on or not, may benefit the client if the total moves the portfolio value into the next tier of the fee schedule. The fee is based on the following fee schedule: Investment Management Portfolio Value Annual Fee On the first $1,000,000 1.50% Between $1,000,001 and $2,000,000 1.25% Between $2,000,001 and $5,000,000 1.00% Above $5,000,000 0.75% RPATA may offer a lower fee schedule with a separate fee rate for an account in certain specific investment strategies and services. Currently, RPATA offers an Income Strategy and discounts the rate for assets in those accounts to 0.25% annually. Additionally, the Firm offers a reduced service for maintaining accounts as transferred. These accounts are charged 0.25% annually. The Firm reserves the right to create additional fee schedules consistent with other strategies. The annual fee is prorated and charged quarterly. In most circumstances, charges are in advance, based upon the market value of the assets managed by RPATA on the last day of the previous billing period. However, certain custodians require billing to be done in arrears. In this case, the fee is based upon the market value of the assets managed by RPATA on the last day of the billing period. If assets in excess of $20,000 are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted on a pro rata basis to reflect the change in portfolio value. The activity is analyzed at the end of each month. If the net activity over that calendar month reaches the threshold, the activity is marked and included in the adjustment calculation. Deposits are billed within 10 business days of the subsequent month. Withdrawals are netted out of the subsequent quarter’s calculated fee. In situations when

the account fee for the subsequent quarter is not large enough to cover the rebate fee, an adjustment for the difference is made and posted back to the account. For the initial period of an engagement, the fee is calculated on a pro rata basis. If the fee is calculated in arrears, the charge will be on the last day of the quarter. If charged forward, the fee will be charged within 10 business days of the subsequent month the account was opened. In the event the Agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination. For forward billing, the unearned portion is refunded. Accounts with arrears billing will have a final bill assessed at the time of termination. In both methods, a report describing the rebate to the client, is provided. Retirement Plan Consulting Fees RPATA may charge a fixed project-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary and are based on the scope of the services to be rendered. In situations where RPATA has agreed to manage a plan’s assets, the Firm may also charge an annual asset-based fee, to be determined on an individual basis depending upon the amount of assets to be managed and the services to be provided. The asset-based fee is facilitated by the recordkeeper on the plan and will either be charged in arrears based on the aggregated value of the plan assets on the last day of the quarter or charged forwards based on the aggregated value of the plan assets on the last day of the previous quarter. Partial periods are pro-rated using the actual number of calendar days the assets were managed. Each Retirement Plan Consulting Agreement clearly details the fees to be charged and the methodology used, specific to the recordkeeper on the plan. Fee Comparison A portion of the fees paid to RPATA are used to cover the securities brokerage commissions, transactional costs attributed to the management of its clients’ portfolios, and the fees charged by the Independent Managers engaged to provide services under the Program. Independent Managers servicing accounts through the Program receive a fee based upon the assets under their management which is paid by RPATA from the Program fee. Services provided through the Program may cost clients more or less than purchasing these services separately. The Program may create a potential conflict of interest between clients and the Firm because RPATA pays the transaction costs associated with trades directed to the custodian. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. The Program may result in higher overall costs to the client in accounts that experience little trading activity, and this presents a disincentive for RPATA to purchase or sell securities in the client account. RPATA strives to uphold its duty to clients despite this conflict. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Revolution Partners, LLC does not charge an additional fee for the services provided to RPATA clients. Since ATA does not provide any services under the Agreement, any additional fees charged by ATA are beyond the scope of services provided under the Agreement. Each client’s relationship with ATA, if any, is governed by a separate agreement between the client and ATA. Fees for services provided by RPATA and ATA are billed separately. Fee Discretion RPATA, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention and pro bono activities. The advisory fee is agreed upon in advance and documented in the Agreement signed at the beginning of each relationship. Fee Debit The Firm’s Agreement and the separate agreement with any Financial Institutions generally authorize RPATA to debit its clients’ accounts for the amount of the Program fee and to directly remit that fee to RPATA. Any Financial Institutions recommended by RPATA have agreed to send statements to clients not less than quarterly indicating all amounts disbursed from the account, including the amount of Program fees paid directly to RPATA. Clients also receive from RPATA a quarterly invoice detailing the amounts deducted for participation in the Program, as required under applicable state securities laws. After the first fee report is delivered, fees are reported in the quarterly portfolio report, including total fees paid since the inception of the account with the Firm. Within a quarter, additional billing will occur in case of large qualifying contributions or withdrawals, new or terminating accounts, or changes to the client’s fee schedule. If necessary, prorated rebates for fees are credited to accounts at the end of the quarter, for example on assets withdrawn or previously billed assets subject to a new fee schedule. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to RPATA, subject to the usual and customary securities settlement procedures. However, RPATA designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. RPATA may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. Other Charges In addition to the advisory fees paid to RPATA, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges may include securities brokerage commissions, transaction fees, custodial fees, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), 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. RPATA does not receive any portion of these commissions, fees, and costs. Neither RPATA nor any of its employees receives compensation for the sale of securities or other investment products. Clients are not charged administrative costs for portfolio accounting. The client will not be charged additional transaction commissions or management fees by the custodian or professional money managers in the normal course of business as directed by RPATA. However, certain activity by the client may result in additional fees to be charged by the custodian to the client. Examples include wire transfers, overnight delivery of checks or documents from the custodian, requests for a physical stock certificate, etc. RPATA strives to give notice to clients before such a charge may be incurred. Compensation for Recommending the Program RPATA has no internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation as a result of clients’ participation.