A. Description of the Advisory Firm B. Types of Advisory Services to an IRA that is subject to their management, FPAI will charge clients an asset-based fee as described in Item 5 below. This practice presents a conflict of interest because persons providing investment advice on FPAI's behalf have an incentive to recommend a rollover to clients for the purpose of generating fee-based compensation. Clients are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if clients do complete the rollover, clients are under no obligation to have the assets in an IRA managed by FPAI. Selection of Other Advisers FPAI may direct clients to third-party investment advisers. Before selecting other advisers for clients, FPAI will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where FPAI is recommending the adviser to clients. Services Limited to Specific Types of Investments FPAI generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities or non-U.S. securities. FPAI may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading

statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. FPAI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent FPAI from properly servicing the client account, or if the restrictions would require FPAI to deviate from its standard suite of services, FPAI reserves the right to end the relationship. A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. FPAI does not participate in any wrap fee programs. FPAI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 0.00 $ 90,930,000.00 December 2023 Portfolio Management Fees Total Assets Under Management Annual Fees All Assets 1.00% FPAI uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of FPAI's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. C. Client Tailored Services and Client Imposed Restrictions D. Wrap Fee Programs E. Assets Under Management