GWMIA offers asset management services which involves GWMIA providing you with continuous and ongoing supervision over your specified Accounts. GWMIA offers its asset management services on a wrap fee basis, which means you pay one fee which covers both asset management and implementation of our recommendations. GWMIA Wrap Free Program GWMIA will recommend an investment program (“Wrap Fee Program”) in which certain transactional costs are included in the client’s management fee (“Wrap Fee”). Fees included in the Wrap Fee include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark-downs, spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades executed by a broker-dealer other than Schwab Advisor Services. Because of the nature of a Wrap Program, the Wrap Program client may pay more or less than if the client were able to buy and sell investments outside of a wrap fee program. For example, if a client’s account is rarely traded, the transaction fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and transaction fees. However, GWMIA does not offer non-wrap fee accounts. Clients are free to explore other investment advisers that offer non-wrap fee programs. To participate in the Wrap Fee Program, you must appoint our Firm as your investment adviser of record on specified Accounts (collectively, the “Account”). The Account consists only of separate Account(s) held by Fidelity Brokerage Services LLC as qualified custodian through the Fidelity Institutional Wealth Program (collectively referred to as Fidelity) under your name. Fidelity, as qualified custodian, maintains physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account on a discretionary or non-discretionary basis as agreed upon with you. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your Accounts, including the ability to instruct us not to purchase certain securities. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal Accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own Accounts. Conflicts may arise in the allocation of investment opportunities among Accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your Account(s) and other Accounts advised by our Firm among such Accounts equitably and consistent with the best interests of all Accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. GWMIA may provide recommendations to the client to utilize one or more specific sub-adviser(s) (individually “Sub- Adviser” and collectively “Sub-Advisers”) to manage the Account or a portion of the assets of the Account. When a Sub-Adviser is selected, the Sub-Adviser will have discretionary authority on your Account to place trades and make changes to the Account or the portion of your Account the Sub-Adviser is authorized to manage. GWMIA only recommends Sub-Advisers who manage within a Wrap Fee, which is typically sponsored by the Sub-Adviser. A complete description of the Sub-Adviser’s services, practices and fees will be disclosed in the Sub-Adviser’s Form ADV Part 2A Appendix 1 that will be provided to the client. GWMIA will conduct due diligence of any recommended Sub-Adviser and monitor the performance of Sub-Adviser with respect to the Sub-Adviser’s management of the designated assets of Account relative to appropriate peers and/or benchmarks. Although GWMIA reviews the performance of numerous third-party investment adviser firms, GWMIA enters into only a select number of relationships with third-party investment adviser firms that have agreed to pay us a portion of the overall fee charged to our clients. Therefore, GWMIA has a conflict of interest in that it will only recommend third-party investment advisers that have a sub-advisory relationship with GWMIA. Clients are advised that there may be other third-party managed programs not recommended by the Firm, that are suitable for the client and that may be more or less costly than arrangements recommended by the Firm. GWMIA will be available to answer questions client may have regarding any portion of client’s Account managed by a Sub-Adviser and will act as the communication conduit between the client and the Sub-Adviser. The recommendation of Sub-Advisers and investments may be done on a discretionary or non-discretionary basis with the specific terms outlined in your Advisory Agreement. When a client authorizes GWMIA to have the ability to select Sub-Advisers and investments on a discretionary basis, GWMIA will have the authority to select and terminate Sub-Advisers and also the ability to purchase and sell investments on behalf of the client without the client’s specific approval. Tailor Advisory Services to Individual Needs of Clients GWMIA advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose reasonable restrictions on the Accounts we manage for you, including specific investment selections and sectors. Our financial planning services are always provided based on your individual needs. When providing financial planning services, we work with you on a one- on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. When managing client Accounts through our Firm’s Asset Management Services program, we may manage a client’s Account in accordance with one or more investment models. When client Accounts are managed using models, investment selections are based on the underlying model and we do not develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client’s individual investment goals, objectives and mandates. Fees for Asset Management Services Wrap Fees charged for our asset management services are charged based on a percentage of assets under management. Wrap Fees are billed in arrears (at the end of the billing period) on a monthly calendar basis. Wrap Fees billed in arrears are calculated based on the average daily balance of the account for the preceding calendar month. Wrap Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. Under the average daily balance method, each day’s balance for the month is summed then divided by the number of days in the month,

to compute the average daily balance. The average daily balance is then multiplied by the monthly portion of the annual fee to determine the monthly fee due. The GWMIA services continue in effect until terminated. You may terminate the services by providing GWMIA with notice. GWMIA may terminate the services by providing you with written notice effective 30 days after you receive the written notice. Any prepaid, unearned fees will be promptly refunded by GWMIA to you. Fee refunds will be determined on a pro rata basis using the number of days services are actually provided during the final billing period. Wrap Fees charged for our asset management services are negotiable based on the investment adviser representative providing the services, the type of client, the complexity of the client's situation, the composition of the client's Account (i.e., equities versus mutual funds), the potential for additional Account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. Client will be charged an annual Wrap Fee ranging between .30% to 2.0%. All fees are negotiable. There is no minimum Account size required to open an Account with GWMIA. GWMIA may elect to use a sub-adviser to manage all or part of the assets of client. Fees for such sub-advisers will be paid by GWMIA from the Wrap Fee and clients will not be charged additionally for their services. Sub-advisers generally have account minimum requirements that will vary. Account minimums are generally higher on fixed income accounts than for equity based accounts. GWMIA does not charge additional management fees for third- party managed or sub-advised account services. The Firm pays higher fees to AE Wealth for sub-advised accounts than the Firm pays for accounts the Firm manages directly via AE Wealth’s platform. For accounts sub-managed by AE Wealth, the fee will not exceed 0.45%, but will most commonly be 0.40%. For accounts managed by GWMIA on the AE Wealth platform, the fee will not exceed 0.20%, but will most commonly be 0.15%. Since the Firm retains the difference between the total advisory fee and the amounts the Firm pays to AE Wealth, the Firm has an incentive to recommend that clients not use a sub-adviser. This incentive creates a conflict of interest. This conflict of interest is lessened by the fact that the Firm incurs internal costs for self-managing an account via the AE Wealth platform. In situations where those internal costs exceed the difference that AE Wealth charges for sub-advised versus Firm-advised accounts, the Firm-advised accounts become less profitable than sub-advised accounts, and the Firm has a financial incentive to recommend a sub-adviser, which creates a conflict of interest. Ultimately, these conflicts of interests are managed by assuring that the recommendations the Firm makes to each client is based on the client’s best interest without regard to costs, and by disclosing this conflict so you, our client, may ask questions about our recommendations. GWMIA retains the difference between the total Wrap Fee paid to GWMIA and any sub-advisory fee. GWMIA therefore has a financial incentive to recommend that clients invest in the sub-advisory programs with the lowest sub-advisory fee. This creates a conflict of interest, as GWMIA is incentivized to recommend sub-advisers based on compensation received by GWMIA rather than based solely on the interests of the client. GWMIA manages this conflict of interest by reviewing all sub-adviser recommendations to ensure such recommendations are suitable and in the client’s best interest. A complete description of the sub-adviser’s or third-party money manager’s services, fee schedules and account minimums will be disclosed in that adviser’s disclosure brochure, which will be provided to you prior to or at the time an agreement for services is executed and the account is established. GWMIA believes that its annual Wrap Fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to our compensation, you may also incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses). The investment advisory fees will be deducted from your account and paid directly to our Firm by the qualified custodian(s) of your account. You will authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to our Firm. The quarterly performance report will include the billing statement and will detail the formula used to calculate the fee, the assets under management and the time period covered. See Item 15 (Custody) of our ADV Part 2A Brochure for more details. You should review your Account statements received from Fidelity or other qualified custodian and verify that appropriate investment advisory fees are being deducted. Fidelity or other qualified custodian will not verify the accuracy of the investment advisory fees deducted. IRA Rollover Considerations As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's/former employer’s retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based compensation rather than based solely on your needs. We manage this conflict of interest by always acting in the client’s best interest and keeping documentation of our determination that the rollover recommendation is in the client’s best interest. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits. An employee will typically have four options: 1. Leaving the funds in your employer's (former employer's) plan. 2. Moving the funds to a new employer’s retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. We will speak with your CPA and/or attorney if you authorize us to do so in connection with any rollover recommendation we make. Similarly, we may rely on information you obtain from your CPA or tax attorney and communicate to us prior to making any such recommendation. Other Fee Terms You should notify GWMIA if you have questions about or dispute any billing entry. At times, GWMIA will refer clients to various outside professionals (i.e., an attorney, independent investment adviser, or accountant) in the course of providing financial planning services. GWMIA does not receive compensation for such referrals. In these instances the outside professional represents the client and GWMIA is not a party to such relationship. Fees for the services of an outside professional will be in addition to and separate from the fees charged by GWMIA, and you will be responsible for the payment of the fees for the services of such an outside professional. GWMIA may, at the Firm’s sole discretion, reimburse the client for all or a portion of the expenses related to such outside professionals. In no event will the services of an outside professional be engaged without your express approval. Typically, the more assets a client has in an advisory account, the more the client will pay in asset-based fees, and we therefore have a conflict of interest based on an incentive to encourage clients to increase the assets in their account We mitigate this conflict of interest by ensuring that our recommendations are made in a client’s best interests.