EM 4 Who We Are Portfolio Design Services, LLC (hereinafter referred to as “the Company”, “we”, “us” and “our”) is a fee-only1 registered investment advisor2 organized in June of 2004. We offer a wide range of financial management services3 designed to assist you, our client4, in achieving your financial goals. Owners The following person controls the Company: Name Title CRD# Bradley C. Olson Managing Member & Research Manager 5342550 Bruce D. Swanson Member 1113446 Angela K. Tille Chief Compliance Officer 7293007 Assets Under Management As of December 31, 2023, our assets under management totaled: Client Discretionary Managed Accounts ......................... $122,066,350 We do not offer non-discretionary investment management services. Our Mission Our mission is to provide personal, caring, and knowledgeable advice to help you clarify goals and realize dreams. We will come along side to guide you through the maze of financial alternatives and provide clear objective advice designed to maximize wealth, maintain investment expectations, and minimize investment risk relative to your financial goals. Services We Offer We offer financial solutions that stress fiscal responsibility and shrewd planning that is not always about the accumulation of assets, which we believe has little to do with real happiness, but what is best for your personal health and well-being. Some of the best advice we could ever offer you is that success, achievement, and contentment in life have little to do with personal wealth but are instead related to lifestyle choices. These lifestyle choices are your 1 As a “fee-only” registered investment advisor, Portfolio Design Services, LLC does not receive compensation from any source other than what is directly paid by you, our client, for the services we provide. 2 The term “registered investment advisor” is not intended to imply that Portfolio Design Services, LLC has attained a certain level of skill or training. It is used strictly to reference the fact that we are “registered” as a licensed “investment advisor” with the United States Securities & Exchange Commission – and “Notice Filed” with State Regulatory Agencies that have limited regulatory jurisdiction over our business practices. 3 Portfolio Design Services, LLC is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or as defined under the Internal Revenue Code of 1986 (the “Code”) for any financial management services provided to a client who is: (i) a plan participant or beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an Individual Retirement Account (“IRA”). 4 A client could be an individual and their family members, a family office, a foundation or endowment, a corporation and/or small business, a trust, a guardianship, an estate, a retirement plan, or any other type of entity to which we choose to give investment advice. unique values, life goals, and plans. Therefore, the economic solutions we develop, whether portfolio management and/or financial/retirement planning, reflect how you define true wealth not us. Our services include: Investment Management Our Investment Management Services are designed to build long-term wealth while maintaining risk tolerance levels acceptable to you. We offer two Investment Management Service options based on your financial needs and or our management limitations. These services include: (1) Portfolio Management; and (2) Investment Consulting. PORTFOLIO MANAGEMENT Our portfolio management strategies focus on managing diversified portfolios of primarily equity (“stock”) positions, fixed income (“bond”) instruments, Exchange Traded Funds (“ETFs”), and some investment company (“mutual fund”) products to achieve the best return on your investment capital relative to your investment parameters. Investment parameters are defined as your personal benchmarks and tolerance to risk. You will find more information about our management fees under “Portfolio Management” in Item 5, “Fees & Compensation” below and further description of our investment strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.” INVESTMENT CONSULTING Investment consulting services are independent of any and all of our advisory services. Under this arrangement, we do not provide any on-going portfolio management, financial planning, or retirement planning of your account. Such consulting may include, but are not limited to: v General and/or specific advice on investment selection v Construction of an Investment Policy Statement v Development of an asset allocation guideline v Retirement analysis You can find more information about our consulting services fees under “Investment Consulting” below in Item 5, “Fees & Compensation”. Financial Planning Financial planning is one of the most important tools that successful people use to create an extraordinary personal life and business career. However, it requires a lifetime commitment, not only from us, the Financial Planner, but from you as well. WHAT IS A FINANCIAL PLAN? Financial planning is an evaluation of the investment and financial options available to you based upon your defined lifestyle choices. Planning includes: (i) attempting to make optimal decisions; (ii) projecting the consequences of these decisions for you in the form of a financial plan – a working blueprint; and (iii) implementing the protocols to achieve the objectives of the plan. Once complete the financial plan, or working blueprint, becomes the plumbline to compare a future financial performance to be sure you are achieving your economic goals and objectives. FINANCIAL PLANNING COMPOSITION A financial plan can be coordinated – a mutually defined review of your personal financial life needs; or, targeted – a review, analysis, and evaluation of a core area of financial need. In general, our financial planning may encompass one or more of the following areas of financial need as communicated by you: v Personal – Family records, budgeting, personal liability, estate information and financial goals. v Education - Education IRAs, financial aid, and state savings plans including 529 plans, grants, and general assistance in preparing to meet dependents continuing educational needs through development of an education plan. v Taxes & Cash Flow – Understanding the impact of various investments on your current income tax and future tax liability. v Death & Disability – Cash needs at death, income needs of surviving dependents, estate planning and income analysis. v Estate – Reviewing estate planning documents, including wills and trusts, to determine if you should seek the assistance of an estate planning attorney. Reviewing powers of attorney, nursing home and assisted living agreements, living trusts, and Medicare/Medicaid benefits. v Retirement – Analysis of current strategies and investment plans to help you achieve your retirement goals. v Investments – Analysis of investment alternatives and their effect on your investment portfolio(s), including a risk and return analysis. Assessment of your risk tolerance profile. v Insurance – Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. PREPARING THE FINANCIAL PLAN In the development of your financial plan, we will follow the Financial Planning Practice Standards process established by the Certified Financial Planner Board of Standards, Inc. Your financial plan will be prepared in four (4) stages. These stages are defined as follows: Stage I: Evaluate Through the detailed evaluation process, we learn about you and what you want to achieve. This is accomplished through personal interviews and profile questionnaires5, which are designed to address all of the financial planning disciplines discussed above. You will have the opportunity to prioritize your objectives and to remove from the process any areas that are not applicable to your circumstances. The time we invest in this evaluation process to listen and cater to your desires is critical for developing a strong financial planning foundation. Such time helps to: v Define and narrow objectives and investment options. v Stimulate creative thinking. v Identify areas of greatest concern. v Cultivate piece of mind. v Create a unique picture of your overall financial personality; and, v Provide an effective and efficient way for us to address your unique financial needs and objectives. 5 The profile questionnaire we use is an important tool in gathering information about your investment methodology, risk tolerance, income/tax bracket, liquidity, time horizons, etc. If you elect not to answer the questionnaire or choose to respond with limited input, it is possible that we could operate in a handicapped capacity contrary to your investment needs. Therefore, if you desire the most effective and accurate recommendations regarding your managed account(s), you should make every effort to provide us with your detailed personal needs and objectives, along with detailed financial and tax information. After the interview process, we will prepare an agenda and conduct a meeting with you to begin formally documenting your goals and objectives. From this meeting, we will draft a report documenting the financial planning process disciplines that you wish to address, detailing the specific objectives under each discipline. Redrafting and meetings can be repeated until you are completely satisfied with the report. Depending upon the engagement, different levels of financial reporting will be undertaken. At a minimum, a statement of financial position, designed for financial planning use only, will be prepared. Stage II: Integrate We define the financial plan as a road map (a series of blueprints) designed to take you from where you currently are financially, to where you want to be at some point in the future. This is the creative portion of the process. There are usually many different ways to accomplish a given goal. The objective, however, is to formulate a plan that you will be comfortable executing. In some cases, the drafting of the plan reveals the need for us to help you reconcile the gap between your expectations and your financial realities. Once a viable plan has been drafted, it is presented to you and reviewed. The draft and review process may be repeated until you are satisfied with the financial plan. Stage III: Formulate A financial plan is of limited value if it is not put into action. Accordingly, we place a premium on implementing6 and monitoring the plan. The implementation schedule provides you with a list of tasks and deadlines designed to ensure that you put your plan into action. The following are some examples of implementation: v Drafting of appropriate estate documents (performed by an estate attorney). v Purchase of various insurance policies (provided by an independent licensed insurance agent of your choice). v Investment advisory services, including preparation of a Investment Policy Statement and Client Profile and asset allocation strategy (performed by us, or another investment advisor/broker-dealer of your choice). v Adopting and monitoring of a personal budget. v Ongoing income tax planning (prepared by an independent Certified Public Accountant or tax accountant of your choice). Stage IV: Delegate Once the plan has been built and the recommendations have been implemented it is critical that these recommendations be monitored on a continuing basis to ensure that they remain consistent with your investment objectives. This process requires periodic rebalancing of the portfolio to ensure your original objectives are maintained. Continued monitoring of established personal budgets and the continued effects of taxation on the plan are assessed regularly at your option per the Annual Review. You will find more information about our financial planning fees under “Financial Planning” below in Item 5, “Fees & Compensation”. 6 Implementing the recommendations made in a financial plan often requires consultation or coordination with one or more outside professionals (e.g.: attorneys, CPAs, insurance and securities representatives). All information provided by and received from you will be kept entirely confidential, not only by us, but by the outside professionals as well. Such information will be disclosed to third parties only with mutual consent or as may be permitted or required by law. Retirement Planning We assist employer-sponsored retirement and savings plans in the design of the fiduciary governance structure and in the development and execution of an investment management program. Depending on the desire of the employer-sponsored plan we can provide the following services under ERISA: v Limited-Scope 3(21) Fiduciary – As a Limited-Scope 3(21) advisor, we acknowledge we have a fiduciary role but do not take discretion. We provide investment advice to the plan sponsors and/or Named Fiduciary who are ultimately responsible to make the investment decisions. v 3(38) Advisor – As a 3(38) advisor, we have full discretion for investment selection, monitoring, and replacing investment options with authority to buy and sell securities. Under this arrangement, the Full-Scope ERISA 3(21) advisor is outsourcing all investment management decisions to us. v Full-Scope 3(21) Fiduciary – As a Full-Scope 3(21) Fiduciary, we will be the plan sponsor or other Named Fiduciary. A Full-Scope 3(21) Fiduciary is a fiduciary that has complete discretion authority to make all investment management decisions, full responsibility to manage operations of the plan, and to hire/fire other Limited- Scope 3(21) advisors and/or 3(38) Advisors. DESIGNING A RETIREMENT PLAN In working with plan sponsors and fiduciaries that have already created, or with the committee looking to create, an employer-sponsored retirement plan, we will adhere to the standards of care required by ERISA professional practice standards in advising on the existing retirement plan or in the creation of a new retirement savings plans. Our services generally follow these five steps: Step 1: Review Current Investment Architecture If the employer has an existing retirement plan, we will conduct a fiduciary review of the retirement plan’s current investment activities. This includes reviewing existing trust documents and the plan’s current Investment Policy Statement. Money Managers and/or mutual fund structures and fees (including transaction costs) will be scrutinized. We will also examine recordkeeping and administration expenses and will confirm bonding requirements are currently being satisfied. In addition, we will review and evaluate strategic investment strategies and policies, and all existing contracts. As a Limited-Scope 3(21) Fiduciary, this step is intended to help the sponsor and/or the plan’s Named Fiduciaries (Full-Scope 3(21) Fiduciaries) identify, confirm, and measure objectives, concerns, and performance in managing the plan. We will take steps to educate fiduciaries about their responsibilities and duties. Moreover, we will use this education process as a convenient forum for eliciting feedback and input from existing plan fiduciaries so that the findings in this first step will also reflect the knowledge and experience and insights of the existing fiduciary team. Step 2: Design the Optimum Portfolio/Menu Identify diversification and optimization approaches for the plan to effectively control individual asset allocation decisions. The asset classes and various asset class combinations that will be made available to the plan need to be identified. The identification of the asset classes to be made available requires a consideration of anticipated returns and risk measures, as well as the historical correlation coefficients between asset classes. This work will result in setting the foundation for the management approach to appropriately diversify and optimize the investments that will be included in the investment menu and reflected in the investment policy. Step 3: Formalize the Investment Policy We will draft, or amend, a written investment policy that will address specific plan and investment objectives, the various asset classes and alternative asset class combination funds to be included, as well as the investment guidelines and procedures for selecting and monitoring Money Managers. Step 4: Implement Investment Policy We will propose a number of alternative third-party Money Managers for the fiduciary or trustee consideration. The proposal will include a review of active and passive alternatives. We will consider the individual management styles and disciplines that each fund or manager is expected to bring to the total portfolio. If we have been appointed as a Limited-Scope 3(21) Fiduciary, the Company is willing to take on the role of an “investment manager” as defined in ERISA 3(38). In this capacity, we will have discretion over constructing the investment menu, and will select and monitor Portfolio Managers and mutual funds. With us serving in this role, the plan’s named fiduciaries will be able to actively participate in reviewing the professional recommendations of their investment manager while avoiding what too often turns out to be a dysfunctional bifurcation of authority and expertise. Step 5: Monitor the Investment Program Most importantly, we will provide ongoing supervision of the investment program, and will submit and present quarterly performance reports comparing the returns of each investment in the portfolio/menu against stated investment objectives, and the policy benchmarks. On a regular basis, we will assess the qualitative and organizational structures affecting each of the plan’s investments. Generally, we will keep the fiduciaries/trustees appraised of the overall costs of the plan, and material changes in any investments that are being utilized. Evolving economic, financial, and competitive developments will be included as part of the Company’s ongoing monitoring. We will also monitor the revenue paid to any provider of the plan. You can find more information about our retirement planning fees below under “Retirement Planning” in Item 5, “Fees & Compensation” below and further description of our retirement planning strategies under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.” FEES & COMPENSATION IT 5 Portfolio Management Portfolio management is provided on an asset-based fee7 arrangement. Management fees are calculated based on the aggregate market value of your account on the last business day of the previous calendar quarter multiplied by the corresponding annual percentage rate for each 7 An asset-based fee is a percentage fee charged based on your assets under management for our professional time giving continuous advice, managing investment strategies, and suggesting investment options. We receive no other compensation for this advisory service unless first disclosed to you. portion of your portfolio assets that fall within each tier (see “Billing” below under “Protocols for Portfolio Management” for more information on how the fee is calculated). We retain discretion to negotiate the management fee within each tier on a client-by-client basis depending on the size and complexity of the portfolio managed. In addition, a fee break will occur as assets in your portfolio increase past the following tier: Account Balance Annual Fee Rates Not to Exceed Fixed Income Rates Not to Exceed First $1,000,000 ............................ 1.50% 0.30% Next $1,000,000 ............................ 1.25% 0.25% Next $3,000,000 ............................ 1.00% 0.20% Over $5,000,000 ............................ 0.75% 0.15% We have the option to require a minimum initial investment of $100,000 to open any managed account. We also have a $240 minimum annual fee requirement ($60 billed quarterly), which may be waived or reduced if we feel circumstances are warranted. Accounts with portfolio values that fall below $12,000 will be subject to this minimum annual fee, which can cause our fee to exceed our highest published 2.00% Annual Fee Rate (e.g., a managed account of $10,000 with a minimum annual fee charge of $240, will translate into an annual fee rate of 2.40%.). Keep in mind, the further your portfolio value drops below $12,000 the higher the annual fee rate. Protocols for Portfolio Management The following protocols establish how we handle our portfolio management accounts and what you should expect when it comes to: (i) managing your account; (ii) your bill for investment services; (iii) deposits and withdrawals in/from your account(s); (iv) other fees charged to your account(s); and (iv) termination. DISCRETION We will establish discretionary trading authority on all management accounts to execute securities transactions at any time without your prior consent or advice. At any time however, you may impose restrictions, in writing, on our discretionary authority (i.e., limit the types/amounts of particular securities purchased for your account, exclude the ability to purchase securities with an inverse relationship to the market, limit our use of leverage, etc.) BILLING Your account will be billed a blended fee quarterly in advance based on the fair market value for the portion of your portfolio that falls within each tier of our above fee schedule. For example: The Blended Fee for a Portfolio Management Account Assets within Each Tier Aggregate Account Value: $4,200,000 Annual Fee % (Per Tier) Tier Fee Contribution (Based on

the Account Value Within Each Tier) $1,000,000 1.50% 0.3571% $1,000,000 1.25% 0.2976% $2,200,000 1.00% 0.5238% Blended Annual Fee %: 1.1785% For new managed accounts opened in mid-quarter, our fee will be based upon a pro-rated calculation of your assets to be managed for the current quarterly period. Advisory fees will be deducted first from any money market funds or cash balances. If such assets are insufficient to satisfy payment of such fees, a portion of the account assets will be liquidated to cover the fees. ACCOUNT SET-UP FEE New management accounts may be assessed a one-time set-up fee for: (i) the time expensed in preparation of internal records for portfolio management and data preparation based on your Investment Policy Statement and Profile; (ii) the administrative services involved in the transfer of your asset management accounts to our custodian; and, (iii) general telephone consultations and research to finalize the account set-up process. The set-up fee is based on our $250 hourly rate and is non-refundable should you wish to terminate the Investment Advisory Agreement due to time we expensed to create the management accounts. The exact amount of the set-up fee you will be charged will be fully disclosed in the Investment Advisory Agreement. DEPOSITS AND WITHDRAWALS Assets you deposit into your management accounts between billing cycles may result in additional management fees being billed to your account. Such deposits, in most cases, will require modifications and adjustments to your investment allocation. Therefore, a pro-rata fee based upon the number of days remaining in the current quarterly period may be assessed for deposits. For assets you may withdraw during the quarter, we do not make partial refunds of our portfolio management fee. Just as with deposits, withdrawals may require modifications and adjustments to be made in the portfolio to correct the allocation of assets. MANAGEMENT FEE EXCLUSIONS Custodial Fees The above fees for portfolio management are exclusive of any charges imposed by the custodial firm(s) who has custody of your account; including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, such as, postage/handling fees, electronic fund and wire transfer fees, auction fees, debit balances, margin interest, certain odd-lot differentials and mutual fund short-term redemption fees; and (iv) brokerage and execution costs associated with securities held in your managed account. There can also be other fees charged to your account that are unaffiliated with our management services. There can be no assurance that Charles Schwab & Co., Inc. (“Schwab”) will not change its transaction fee pricing in the future. These fees/charges are in addition to our management fee. We do not receive any portion of Schwab fees/charges. Investment Company Fees All fees paid to us for portfolio management services are separate from any fees and expenses charged on mutual fund shares by the investment company or by the investment advisor managing the mutual fund portfolios. These expenses, which we do not share in, generally include management fees and various fund expenses, such as 12b- 1 fees. Redemption fees, account fees, purchase fees, contingent deferred sales charges and other sales load charges may occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds is contained in each mutual fund’s prospectus. You are encouraged to carefully read the fund prospectus. Held-Away Assets We have entered a third-party agreement with Pontera Solutions, Inc. (“Pontera”) enabling us to manage and trade on held-away assets, such as defined contribution plan (i.e., 401(k) and 403(b)) participant accounts, annuities, 457 deferred compensation plans, and 529 education savings plans. The Pontera platform links held-away assets in a single interface for a more comprehensive view of your retirement assets and the ability for us to implement asset allocation and opportunistic rebalancing strategies that would otherwise be constrained due to regulatory limitations related to federal and state custody laws. How It Works Pontera will provide a secure link for you to gain access to their platform. There you will provide detailed information relating to your held-away assets and establish the login credentials to those accounts. We will never have direct login capability to those held-away assets. You maintain personal autonomy allowing us to only allocate and trade those accounts you linked to the Pontera platform. Once you give us entitlement to manage those held-away assets, we can structure asset allocations strategies and use our account management software to create a seamless management process. Disclosures v Pontera charges an asset-based annual fee of 0.30% for each retirement account we manage on their platform. The fee is calculated at the beginning of each calendar quarter (i.e., 0.30% ÷ 4 = 0.075%) and billed to us – you do not pay directly for this service. This will NOT result in you paying a higher management fee above what we have currently disclosed in our above fee schedule. v Our investment advice is limited by the investment choices available within your retirement plan, and we are not responsible for any costs, expenses, transaction fees, redemption fees, penalties or otherwise resulting from any account transactions. v We will not have, nor will we accept, any authority to change beneficiaries or effect account disbursements or to process any transfers of any funds to/from your retirement account(s). v We are independent of and not owned by, affiliated with or sponsored or supervised by Pontera, or any of their affiliates. Termination of Portfolio Management Services To terminate our investment advisory services, either party (you or us) by written notification to the other party, may terminate the Investment Advisory Agreement at any time, provided such written notification is received at least 30 days prior to the date of termination (i.e.; To terminate services on October 1st, a request for termination should be received in our office by September 1st.). Such notification should include the date the termination will go into effect along with any final instructions on the account (i.e., liquidate the account, finalize all transactions and/or cease all investment activity). In the event termination does not fall on the last/first day of a calendar quarter, you shall be entitled to a pro-rated refund of the prepaid quarterly management fee based upon the number of days remaining in the quarter after the termination notice goes into effect. Once the termination of investment advisory services has been implemented, neither party has any obligation to the other – we no longer earn management fees or give investment advice and you become responsible for making your own investment decisions. Investment Consulting Our Investment Consulting fee will not exceed $250 per hour for our advice. Investment consulting services are independent of our Portfolio Management, Financial Planning and/or Retirement Planning services. Under this arrangement, we do not provide any on-going management of your account or give continuous investment advice. We will perform the desired task, but you are responsible for implementing any of the advice. However, in the case of us preparing an asset allocation model from an Investment Policy Statement we prepared for you, you can contact us to schedule a quarterly review of your portfolio allocation to determine how the account is performing. We will review the account and make any recommendation, if necessary, for you to rebalance the account. Billing At minimum, we require four (4) hours of initial consultation8 to conduct an adequate interview to determine your investment needs, goals, and objectives to adequately provide the service you desire. All consulting fees will be completely itemized in a billing statement or consulting agreement. For the initial consultation, the fee will be due at the end of the session. Thereafter we will bill you at the agreed upon hourly rate, should we be contacted by you for future reviews and advice on any re-balancing. Termination Investment consulting services can be terminated at any time. Financial Planning How we charge to develop a financial plan depends on the size, complexity, and nature of your personal and financial situation and the amount of time it will take to analyze and summarize the plan and perform the services you desire. 8 If you were to pay $1,000 (4 hours @ $250 per hour) for the initial consultation and then contacted us for hour-long quarterly follow-up reviews, this fee could be the equivalent of what you would pay if you were to have us manage your investments based on a percentage of assets under management. For example, to develop a tailored asset allocation mix for an investment portfolio of $90,000, our initial fee of $1,000, along with hour-long quarterly reviews at $250 to make rebalancing recommendations on your account, would be approximately $1,750 for the first year if such consultations were started in the first quarter of the year. Yet if you approached us to manage your investments for an annual fee of 2.00%, the same $90,000 would generate an annual fee of $1,800.00, and it would include continuous investment advice and the monitoring of your account to be sure it was meeting your investment needs and objectives. Planning Fees COORDINATED PLANNING All coordinated financial planning services are offered on a fixed fee basis not to exceed $20,000 for the initial engagement. Coordinated planning fees are significantly reduced if we are providing you additional services, such as Portfolio Management services. The coordinated planning fee will be fully disclosed up-front in a Financial Planning Agreement, which will include the cost9 to review your financial information and prepare the comprehensive financial plan. We have the option to: 1. Require full payment up-front10; 2. Require one-half the fee be paid at the time the Agreement is signed, with the remaining balance due upon completion of the financial plan; or, 3. Require one-half the fee be paid at the time the Agreement is signed, with the remaining balance billed monthly on a progress basis as the work is completed. TARGETED If you desire only targeted planning – review, analysis and evaluation of a core area of financial need – the fee will be billed at our hourly rate not to exceed $25011. All fees will be completely itemized in a billing statement to you, or as otherwise predetermined in a proposal, engagement letter and/or by retainer. Annual Review It is important to note that any planning is kinetic (always in motion) and alive. A financial plan is a roadmap that is only as good as how well it reflects your current economic position to then guide you on a clear path to a future financial destination. However, you can veer off course, intentionally or unintentionally, as circumstances in your life take you down another path. An annual financial plan review is designed to systematically address these unexpected diversions and continually keep you on the right road headed to your future financial destination. ANNUAL REVIEW Once the initial financial planning services have been completed, we will establish future “Annual Review” dates. The Annual Review dates generally begin after the first anniversary and will be to review and make adjustments, if necessary, to the financial plan. Together we will set the calendar dates for your future reviews; inasmuch, an Annual Review may consist of up to three (3) visits during the calendar year. ANNUAL REVIEW FEE We reserve the option to waive our annual review fee if we are currently managing your investments. If we are not managing your investment portfolio and you want us to review your financial plan, we will notify you of the cost to perform the desired work before commencing. Such retainer fee will generally range from 25% to 40% of the first- 9 Rarely will a fee exceed those costs outlined in the Agreement. However, there can be instances where we did not contract with you to perform a particular task and therefore merit notifying you of the additional cost prior to beginning such services. 10 The recommendations made in a financial plan are generally completed within 30 to 45 days from you signing the Agreement. However, implementing the plan using outside professionals (i.e., attorneys, CPAs, etc...) may require additional time that is out of our control. Therefore when we refer to the completion of the financial plan, we are referring to us (you and us) finalizing your financial benchmarks/objectives before approaching any outside professional. 11 For a Targeted Financial Plan, we require a minimum of four hours consultation to address any personal and financial needs you may have. year planning fee depending on the length of time since our last review and on the services you request (i.e., If the first year planning fee was $5,000, the annual review fee would be from $1,250 to $2,000.). However, if you have experienced significant change in your life circumstances since the date of your previously prepared plan, the fee could be exceedingly higher. Termination COORDINATED OR TARGETED PLANNING TERMINATION You can terminate the Financial Planning Agreement at any time prior to the presentation of any final planning documents. We will be compensated through the date of termination for time spent in design of such financial documents at the hourly rate agreed to in the Agreement. If you have prepaid any fees, such un-earned fees will be returned on a pro- rata basis. After the financial plan has been completed and presented to you, termination of the Agreement is no longer an option. ANNUAL REVIEW TERMINATION Annual Review services can be terminated at any time. We will bill you for any services rendered from the date of the last bill up to the date of termination at the fee rate that was agreed to in the proposal, engagement letter and/or retainer agreement. Retirement Planning Retirement planning services are provided on an asset-based fee arrangement. Management fees are calculated based on the aggregate market value of the assets in the plan on the last business day of the previous calendar quarter multiplied by the corresponding annual percentage rate for each portion of your portfolio assets that fall within each tier (see “Billing” above under “Protocols for Portfolio Management” for more information on how the blended fee is calculated). We retain discretion to negotiate the management fee within each tier on a client-by-client basis depending on the size, complexity, and type of retirement planning desired. In addition, fee breaks will occur as assets in the retirement plan increase past the following tiers: Pension Plan Account Balance Annual Fee Rates for... ERISA 3(21) Limited-Scope Advisor ERISA 3(38) Advisor ERISA 3(21) Full-Scope Advisor First $2,500,000 ...................................... 1.00% 1.20% 1.40% Next $2,500,000 (Up to and including $5,000,000) ..... 0.80% 1.00% 1.20% Next $2,000,000 (Up to and including $7,000,000) ..... 0.70% 0.90% 1.10% Next $3,000,000 (Up to and including $10,000,000) .... 0.60% 0.80% 1.00% Over $10,000,000 .................................... 0.50% 0.70% 0.90% Protocols for Retirement Planning Services The following protocols establish how we handle our retirement and savings planning accounts and what the plan fiduciaries and trustees should expect when it comes to: (i) managing the retirement plan; (ii) our bill for retirement planning services; and, (iii) other fees charged to the retirement plan. MANAGING THE RETIREMENT PROGRAM The investment allocation models we put together for the retirement plan are based on the investment disciplines that most closely resemble the retirement plan’s investment objectives and risk tolerance as outlined in the Investment Policy Statement. We will offer: v Customized mutual fund allocation models with each model consisting of varying target asset allocations. v Customized open architecture platform of leading third-party portfolio managers (“Portfolio Manager”). v Construction tools to implement effective investment portfolios. v Provide plan sponsors and Named Fiduciaries – if we are not the Full-Scope 3(21) Fiduciary – with online reporting and account access. Once the retirement plan account has been established, depending on the level of engagement we will perform one of the following (These are summary descriptions of service – full description will be made in the Investment Advisory and Management Agreement.): Limited-Scope 3(21) Fiduciary: Non-Discretionary Monitoring Services As a Limited-Scope 3(21) Fiduciary, we are a fiduciary but do not have discretion of the retirement plan. We will continuously monitor the performance of each allocation model and/or Portfolio Manager to be sure the investment objectives are being met and notify the plan sponsor and/or Named Fiduciaries of our recommendations on rebalancing and whether the Portfolio Manager(s) is meeting the investment objectives as outlined in the Investment Policy Statement. 3(38) Advisor: Discretion As a 3(38) Advisory, the Full-Scope 3(21) Advisory has outsourced all investment management decisions to us. We will establish discretionary trading authority on the retirement plan to select, monitor, and rebalance each mutual fund allocation model when necessary, including adding or removing various mutual funds or mutual fund families. In addition, where applicable, we will review the performance of the Portfolio Manager(s), and hire/fire Portfolio Manager(s) based on the investment objectives as outlined in the Investment Policy Statement. Full-Scope 3(21) Fiduciary: Discretionary Monitoring Services As a Full-Scope 3(21) Fiduciary, we will provide operational oversight of the day-to-day activities of the plan. We will establish discretionary trading authority on the retirement plan to select, monitor, and rebalance each mutual fund allocation model when necessary, including adding or removing various mutual funds or mutual fund families. In addition, where applicable, we will review the performance of the Portfolio Manager(s), and hire/fire Portfolio Manager(s) based on the investment objectives as outlined in the Investment Policy Statement. BILLING The retirement plan will be billed a blended fee quarterly in arrears based on the fair market value for the portion of the retirement plan that fall within each tier of our above fee schedule. For new retirement accounts opened in mid-quarter, our fee will be based upon a pro-rated calculation of the retirement plan assets managed for the current quarterly period. FEE EXCLUSIONS The above fees for our retirement planning services are exclusive of any fees paid by the plan fiduciaries and trustees for the services of the retirement planning platform. In addition the fees we collect are exclusive of any charges plan participants may pay that are imposed by a custodial firm, if any, including, but not limited to: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, including, postage/handling fees, electronic fund and wire transfer fees, certain odd-lot differentials, and mutual fund short-term redemption fees; and, (iv) brokerage and execution costs associated with securities held in the retirement account. There can also be other fees charged to the retirement plan that are unaffiliated with our management services. Furthermore, all fees paid to us for retirement planning services are separate from any fees and expenses charged on mutual fund shares by the investment company or by the investment advisor managing the mutual fund portfolios. These expenses generally include management fees and various fund expense, such as: 12b-1 fees. Redemption fees, account fees, purchase fees, contingent deferred sales charges, and other sales load charges may occur but are the exception within managed accounts at institutional custodians. A complete explanation of these expenses charged by the mutual funds is contained in each mutual fund’s prospectus. You are encouraged to carefully read the fund prospectus. Termination of Retirement Planning Services To terminate retirement planning services, either party (the plan sponsor or Named Fiduciaries or us) by written notification to the other party, may terminate the retirement plan Investment Advisory and Management Agreement at any time, provided such written notification is received at least 60 days prior to the date of termination. Such notification should include the date the termination will go into effect along with any final instructions on the plan service. In the event termination does not fall on the last/first day of a calendar quarter, we will be entitled to bill the retirement plan a pro-rated quarterly management fee based upon the number of days in the quarter that the retirement plan was managed before the termination notice went into effect. Once the termination of retirement planning services has been implemented, neither party has any obligation to the other – we no longer earn management fees or give investment advice and the plan sponsor and Named Fiduciaries become responsible for making investment decisions. PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT IT EM 6 We do not charge fees based on a share of capital gains or the capital appreciation of the assets held in your accounts.