A. INVESTMENT ADVISORY SERVICES The Registrant generally provides discretionary investment advisory services through its wrap fee program. See the discussion below under Adkins Seale Wrap Program. Clients in the Program will pay a single fee for bundled services (i.e., investment advisory, brokerage, custody). ADKINS SEALE WRAP PROGRAM The Registrant provides investment management services on a wrap fee basis through the Registrant’s investment management wrap fee program (the “Program”). Under the Program, the Registrant provides discretionary investment management services, for a single specified annual Program fee, inclusive of trade execution, custody, reporting, and investment management fees. All prospective Program participants should read both the Registrant’s Brochure and this Program Brochure, and ask any corresponding questions that they may have, prior to participation in the Program. Charles Schwab & Co. Inc. (“Schwab”) serves as the custodian for Program accounts. The Registrant’s annual investment Program fee is based on a percentage of the market value of a client’s assets placed under the Registrant’s management as follows: Market Value of Portfolio Annual fee as % of First $250,000 1.20% Next $250,000 1.00% Next $500,000 0.85% Next $1,000,000 0.70% Next $3,000,000 0.50% Above $5,000,000 Negotiable By way of example, a client placing $350,000 under Registrant’s management under the above fee schedule would be assessed an annual fee of 1.20% on the first $250,000 placed under Registrant’s management, with an annual fee of 1.00% assessed on the remaining $100,000. Under the Program, the Registrant will have the 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 the Registrant. Clients may change these limitations by notifying the Registrant, in writing, at any time. The client shall have reasonable access to one of the Registrant’s investment professionals to discuss their account. Fee Calculation: The fee charged is calculated as described above and is not charged based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client. In the event that the client withdraws or deposits $10,000 or more into their accounts, the Registrant will either provide a credit against the withdrawal or apply its fee to the contribution the following quarter. Fee Payment: Clients will be charged in advance, at the beginning of each calendar quarter based upon the market value of the assets on the last business day of the previous quarter. Clients may elect to have the Registrant’s advisory fees deducted from their custodial account. In determining market value, the Registrant’s reporting software includes accrued interest, but does not include accrued dividends. Termination of Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of prior written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. 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 the Registrant) may not: (1) achieve their intended objective; (2) be profitable; or, (3) equal historical performance level(s) or any other performance level(s). Client Responsibilities: In performing any of its services, the Registrant shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Furthermore, unless the client indicates to the contrary, the Registrant shall assume that there are no restrictions on its services, other than to manage the account in accordance with the client’s designated investment objective. Moreover, it remains each client’s responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Registrant’s previous recommendations and/or services. B. Participation in the Program may cost more or less than purchasing such services separately. The Program fee charged by Registrant for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. Because Program transaction fees are paid by the Registrant to the account custodian/broker-dealer, the Registrant has an economic incentive to minimize the number of trades in the client's account or select securities that do not incur transaction fees. Depending upon the percentage wrap-fee charged by the Registrant 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. C. The Program’s wrap fee does not include certain charges and administrative fees, including, but not limited to, mark-ups and mark-downs, transfer taxes, odd lot differentials, exchange fees, interest charges, American Depository Receipt agency processing fees, wire 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. These fees and expenses are in addition to the Program fee. In addition, client accounts may invest in mutual funds (including money market funds) and ETFs that have various internal fees and expenses (i.e., management fees), which are paid by these funds but ultimately borne by clients as a fund shareholder. These internal fees and expenses are in addition to the fees charged by the Registrant. When beneficial to the client, individual fixed-income or equity transactions may be effected through broker-dealers that the Registrant or the client have entered into arrangements for prime brokerage clearing services, including effecting certain client transactions through other broker-dealers. In that case, the client generally will incur both the transaction fee charged by the executing broker- dealer and a “trade away” fee charged by the custodian (i.e., Schwab). For Program clients, commissions and trading fees, including trade away fees, are paid for by the Registrant. Schwab does not currently charge transaction fees on U.S. equities, exchange-traded funds, and certain “no-transaction fee mutual funds”. We generally make investment decisions without regard to transaction fees D. Registrant’s related persons who recommend the Program to clients do not receive compensation specifically tied to a client’s participation in the Program. However, the Registrant’s owners receive compensation in proportion to their ownership in the Registrant. For more information, see your representative’s brochure supplement.