A. Description of the Advisory Firm B. Types of Advisory Services Signaling Services WS provides investment advisers with a subscription to certain investment selection models. WS creates and provides signaling services models to the investment advisers based on parameters they set forth. Services Limited to Specific Types of Investments WS generally limits its investment advice to mutual funds, real estate funds (including REITs), equities, fixed income, ETFs (including ETFs in the gold and precious metal sectors) and non-U.S. securities. WS may use other securities as well to help diversify a portfolio when applicable. WS offers the same suite of services to all investment advisers that are WS clients. However, specific investment strategies and their implementation are dependent upon the direction of the investment adviser. WS assists the primary investment adviser in the development and preparation of an Investment Policy Statement that describes their overall investment policies, objectives and guidelines, including, without limitation, asset allocation guidelines and investment restrictions and preferences. WS creates custom models/sleeves for the primary adviser based on the parameters set forth by the adviser. The primary investment advisers may impose restrictions on investing in certain securities or types of securities. WS reserves the right to end any sub-advisory relationship in accordance with the terms of its agreement with the primary adviser and may end the relationship for a variety of reasons, including in response to an investment adviser’s imposition of additional restrictions. WS does not directly manage any client assets. All assets under the firm’s advice are offered through “sponsor” firms who should provide their firm’s ADV Brochure at the time of opening your account. C. Client Tailored Services and Client Imposed Restrictions E. Assets Under Management WS offers its investment

strategy and portfolio modeling services to other investment advisers, including UMA programs, and WS receives a share of the fees the primary investment adviser collects from its underlying clients. The notice of termination requirement and payment of fees for sub-advisory services will depend on the terms of the WS agreement with the primary investment adviser. The fees received by WS will not exceed .60% annually. These fees are generally negotiable. The primary advisers may request that WS’ advisory fees be withdrawn from the underlying client accounts through the Platform or the investment adviser may be invoiced for such fees. The primary adviser will pay WS its portion of such advisory fees in accordance with the applicable sub-advisory contract between WS and the primary investment adviser, on a monthly or quarterly basis based on the terms of the agreement. WS’ client, the primary investment adviser, and the primary adviser’s underlying clients will be responsible for the payment of all third-party fees (including, without limitation, any custodian fees, brokerage fees, mutual fund fees, distribution fees, shareholder servicing fees, transaction fees, Platform fees, taxes, fees of other service providers or consultants engaged by the primary investment adviser, etc.). Those fees are separate and distinct from the fees and expenses charged by WS. WS, or our affiliate, receives a portion of fees charged by Platforms. Item 10 further describes this arrangement and the conflicts of interest presented. Please see Item 12 of this brochure regarding brokerage practices. WS generally collects fees in advance on a quarterly basis. Certain primary advisers may be billed monthly or quarterly in arrears. Refunds for fees paid in advance will be returned to the primary adviser. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in