Investment Management Services Investment management services are provided through this Wrap Fee Program where participants will receive portfolio management, custodial, reporting and clearing services for one all-inclusive fee. When providing investment management services, the firm not only makes recommendations related to investments, but also implements these recommendations and provides ongoing monitoring and reporting. WAM will assist the client in assessing their current financial situation, financial goals and attitudes towards risk, and will then establish what the firm believes to be an appropriate asset allocation. Clients are required to give the firm discretion to make all investment decisions (discretionary management). Portfolios will be invested in a variety of investment classes, including stocks, bonds, mutual funds, and exchange traded funds, among others. The firm can also recommend the use of outside managers. The advisory representative will recommend changes to a client's portfolio based on market, economic, or political circumstances, and the individual characteristics of the securities in the portfolio. Annual wrap program fees range up to 1.5% and are negotiated based on the complexity of the engagement prior to the start of the engagement. Fees are calculated and charged quarterly in advance based on the balance of assets under management as of the end of the preceding quarter. Fees for the first quarter are based on the balance of assets under management at inception. Fees for partial quarters are prorated based on the number of days assets are under management. Fees are deducted directly from the client’s account. Wrap programs can be terminated by either party at any time with 30 days written notice to the other party, and any unearned fees paid in advance will be refunded.

Wrap program fees include investment management and brokerage charges, but are separate from charges imposed by third parties, such as custodial fees, expense or other charges imposed directly by mutual funds or exchange traded funds, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund transfer fees, and other fees and taxes on brokerage accounts and securities transactions. WAM does not hold client assets but instead requires that they be held by a third party “qualified custodian.” The qualified custodian we use is Charles Schwab & Co., Inc. (Schwab). For our clients’ accounts that Schwab maintains, Schwab does not charge separately for custody services but instead is compensated by charging commissions or other fees on trades that it executes or trades that are executed by other brokers to and from Schwab accounts. Fees applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a certain level of assets at Schwab. We feel this commitment benefits you because we expect the overall rates you pay will be lower than they might be otherwise. Services purchased through this program may cost clients less than purchasing similar services from the firm on a stand-alone basis, in that brokerage costs (if any) are paid on behalf of the client through the Wrap Program. However, since WAM absorbs certain transaction costs in Wrap Program accounts, we have a financial incentive not to place trade orders in those accounts, so clients should be aware that this conflict of interest can exist. Clients are encouraged to compare the costs they incur in this Wrap Program vs. a typical investment management account, as the anticipated level of trading activity will impact the costs associated with each type of arrangement.