Description of Services The Flagship Harbor Advisors Wrap Program (the “Program”) is an investment advisory program sponsored by Flagship Harbor Advisors, LLC (“Flagship”). The Program provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. Flagship is a limited liability company formed on December 17, 2010 in the State of Massachusetts. Flagship became registered as an Investment Adviser Firm in December, 2010. Flagship is owned by David Kaufman. John P. Sawyer, III is Flagship’s Chief Compliance Officer. Flagship provides investment management services on a wrap fee basis in accordance with Flagship’s investment management wrap fee program (the “Program”). The services offered under, and the corresponding terms and conditions pertaining to, the Program are discussed in this Wrap Fee Program Brochure a copy of which is presented to all prospective Program participants. Under the Program, Flagship is able to offer participants discretionary investment management services, for a single specified annual Program fee, inclusive of trade execution, custody, reporting, and investment management fees. The current annual Program fee ranges from 0.25% to 2.0% of the assets placed into the Program. Under the Program, Flagship, if engaged on a discretionary basis, shall be provided with written authority to determine which securities and the amounts of securities that are bought or sold. Any limitations on this discretionary authority shall be included in the written agreement between each client and Flagship. Clients may change/amend these limitations, in writing, at any time. The client shall have reasonable access to one of Flagship’s investment professionals to discuss their account. LPL Financial, a FINRA member broker-dealer (“LPL”) shall serve as the custodian for Program accounts. To join the Program a person must: (1) Complete an investor profile that describes the client’s financial needs, investment objectives, time horizon, and risk tolerance, as well as any other factors relevant to the client’s specific financial situation (the “Investor Profile”) and any other supporting documentation required for the Program; (2) Complete the investment advisory wrap fee agreement (the “Program Agreement”) with Flagship and become a client of the Program; (3) Complete a new account agreement with LPL Financial (“LPL”) or another broker dealer approved by Flagship for participation in the Program (“Broker-Dealer”); and Page | 5 (4) Open a securities brokerage account with LPL or the Broker-Dealer (an “Account”) and deposit those client assets designated for participation in the Program (“Program Assets”) into the Account. Please Note: Investment Performance: As a condition to participating in the Program, the participant must accept that past performance may not be indicative of future results, and understand that the future performance of any specific investment or investment strategy (including the investments and/or investment strategies purchased and/or undertaken by Flagship) may not: (1) achieve their intended objective; (2) be profitable; or, (3) equal historical performance level(s) or any other performance level(s). After an analysis of any information provided by the client to Flagship, Flagship shall assist the client in developing an appropriate investment strategy for the Program Assets in their Account(s) (the “Investment Strategy”). Thereafter, all clients are encouraged to discuss their needs, goals, and objectives with Flagship and to keep Flagship informed of any changes thereto. Flagship shall contact clients at least annually to review its previous services and/or recommendations and to determine whether changes should be made to their Investment Strategy. Management of Your Portfolio All clients in the Program shall grant Flagship discretionary authority to buy, sell, and otherwise trade in the type of securities described in Item 6 (below) for their Account(s) and to liquidate previously- purchased securities that the client has transferred to their Account(s). Program. Assets in the client’s Account(s) shall be managed by one of Flagship’s investment adviser representatives. The Program may recommend that clients authorize the active discretionary management of certain Program Assets by and/or among one or more independent investment managers (“Independent Managers”) to implement a particular Investment Strategy. The terms and conditions under which the client shall engage the Independent Manager(s) may be set forth in separate written agreements between the client and Flagship and (2) Flagship or client and the designated Independent Manager(s). Flagship shall continue to render advisory services to the client relative to the ongoing monitoring and review of account performance, for which Flagship shall receive an annual advisory fee which is based upon a percentage of the market value of the Program Assets being managed by the designated Independent Manager(s). Factors that Flagship shall consider in recommending Independent Manager(s) include the client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, Page | 6 and research. In addition to Flagship’s written disclosure statement, the client shall also receive the written disclosure statement of the designated Independent Manager(s). Neither Flagship nor the client may assign the Program Agreement without the consent of the other party. Transactions that do not result in a change of actual control or management of Flagship shall not be considered an assignment. Also, if elected by the client, Flagship will use a third-party platform, Pontera, to facilitate management of held away assets. The platform allows us to avoid being considered to have custody of Client funds pursuant to Rule 206(4)-2, since Flagship does not obtain client log-in credentials, withdraw funds, write checks, maintain a Power of Attorney, nor claim legal ownership of these accounts. Flagship is not affiliated with Pontera in any way and receives no compensation for using the platform. Once Client accounts are connected to the platform, Flagship will review the current account allocations and when deemed necessary, Flagship will, on a discretionary basis, rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. Fees for Participation in the Program Clients in the Program pay a single annualized fee for participation in the Program (the “Program Fee”). Flagship shall charge an annual fee based upon a percentage of the market value of the assets being managed by Flagship. Flagship’s annual fee shall be prorated and charged quarterly, in advance, based upon the market value of the assets being managed by Flagship on the last day of the previous quarter. The annual fee shall vary (between 0.25% and 2.00%) depending upon the market value of the assets under management. The fee charged is calculated as described above and is not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client. Flagship, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.). Under the Program, clients receive both investment advisory services and the execution of transactions in securities for a single, combined annualized fee, the Program Fee. Participation in the Program may cost the client more or less than purchasing such services separately. The number of transactions made in the Page | 7 client’s Account(s), as well as the commissions charged for each transaction, will determine 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 Fee may be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Clients may incur certain charges imposed by third parties in addition to the Program Fee such as fees charged by Independent Managers, charges imposed directly by a mutual fund or exchange traded fund in the account, which shall be 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. Fees for Management During Partial Quarters of Service For the initial period of participation in the Program, the Program Fee shall be calculated on a pro rata basis. The Program Agreement between Flagship and the client will continue in effect until terminated by either party pursuant to the terms of the Program Agreement. The Program Fee shall be prorated through the date of termination and any remaining balance shall be refunded to the client in a timely manner. Additions may be in cash or securities provided that Flagship reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Flagship may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge) and/or tax ramifications. If assets are deposited into or withdrawn from an account after the inception of a quarter, the Program Fee with respect to such assets will be prorated based on the number of days remaining in the quarter. Fee Differentials: As indicated above, Flagship shall receive an investment advisory fee based upon a percentage (%) of the market value of the assets placed under management (between 0.25% and 2 .00%). However, fees shall vary depending upon various objective and subjective factors, including but not limited to: the representative assigned to the account, the amount of assets to be invested, the complexity of the engagement, the anticipated number of meetings and servicing needs, related accounts, future earning capacity, anticipated future additional assets, and negotiations with the client. Because we shall generally price our advisory services based upon various objective and subjective factors, our clients could pay Page | 8 diverse fees based upon a combination of factors, including but not limited to the market value of their assets, the complexity of the engagement, the level and scope of the overall investment advisory services to be rendered, and negotiations, similarly situated clients could pay diverse fees, and the services to be provided by Flagship to any particular client could be available from other advisers at lower fees. All clients and prospective clients should be guided accordingly. Furthermore, since Flagship’s representatives shall receive a portion of the advisory fee charged to the client, a material conflict of interest arises, because an increase in the management fee paid by the client may result in increased compensation received by Flagship’s representative. Participation in the Program may cost more or less than purchasing such services separately. Also the Program fee charged by Flagship for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. Depending upon the percentage wrap-fee charged by Flagship, the amount of portfolio activity in the client's account, and the value of custodial and other services provided, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately and/or if Flagship were to negotiate transaction fees and seek best price and execution of transactions for the client's account. Wrap Program-Conflict of Interest: Under Flagship’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. Because wrap program transaction fees and/or commissions are being paid by Flagship to the account custodian/broker-dealer, Flagship has an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client's account. The Program’s wrap fee does not include certain charges and administrative fees, including, but not limited to, fees charged by SMAs and/or independent investment managers utilized to manage all or a portion of the client’s portfolio, transaction charges(including mark-ups and mark-downs) resulting from trades effected through or with a broker-dealer other than LPL, transfer taxes, odd lot differentials, exchange fees, interest charges, American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with regard to client accounts. Such fees and expenses are in addition to the Program’s wrap fee. Page | 9 Please Note: Clients who engage Flagship on a wrap fee basis will not incur brokerage commissions and/or transaction or asset based custodial fees in addition to the Program fee. Flagship’s related persons who recommend the Program to clients do not receive compensation as a result of a client’s participation in the wrap fee program. Asset-Based Fees versus Transaction-Based Fee in the Wrap Programs: Custodians such as LPL are compensated for their services which include, but are not limited to execution, custody and reporting. LPL can charge a fixed percentage fee for its services based upon the dollar amount of the assets placed in its custody and/or on their platform (for example: if LPL was to charge an annual percentage of the market value of the client assets in its custody, the fee would include the execution of all account transactions). This is referred to as an “Asset-Based Fee.” In the alternative, rather than a fixed percentage fee based upon the market value of the assets in its custody, LPL could charge a separate fee for the execution of each transaction. This is referred to as a “Transaction-Based Fee.” Under a Transaction Based fee, the amount of total fees charged to the client account for trade execution will vary depending upon the number of transactions that are placed for the account. Flagship has entered into an Asset Based Pricing (“ABP”) arrangement with LPL Financial, which covers all program transaction fees, including ticket charges, commissions, and other charges for trading and custody. Because LPL’s ABP fee is based on a percentage of the value of all program assets other than assets invested or held in cash, money market funds, non- transaction fee mutual funds, and commission-free exchange traded funds (collectively the “Non-ABP- Funds”), a conflict of interest exists as Flagship has an economic incentive to allocate or reallocate program clients assets into Non-ABP-Funds to reduce its overall costs under the ABP arrangement. Because Flagship cannot predict the markets and the amount of trading that will occur in a client account, Flagship generally favors Asset-Based pricing within its wrap program offering because it will fix the amount of the fee paid in relation to trade execution, regardless of the number of transactions that are placed for the account. Flagship’s recommendation that a client enter into an Asset-Based pricing agreement with the account broker-dealer/custodian would depend upon whether, based upon anticipated account size and activity, Flagship reasonably believes that the client would benefit from the available pricing arrangement. However, account investment decisions are often more heavily driven by security selection and anticipated market conditions, as opposed to the amount of commission/transaction fees payable by clients to the account broker-dealer/custodian. However, Flagship, on an annual basis, will conduct a sampling to confirm its belief (given the inability to predict the markets and the corresponding amount of trading that will occur) that Asset-Based pricing continues to be beneficial for its clients. Page | 10 Clients may request at any time to switch between Asset-Based pricing and Transaction-Based pricing arrangements, however, there can be no assurance that the volume of transactions will be consistent from year-to-year given changes in market events and security selection. Therefore, given the variances in trading volume and pricing arrangements, any decision by clients to switch between Asset-Based or Transaction-Based pricing could prove to be economically disadvantageous. Flagship’s annual investment advisory fee shall be prorated and paid quarterly, in advance, based upon the average daily market value of the client’s account.