BFG is the sponsor and manager of a wrap fee program, the BFG Wrap Program (“Program”). The Program operates under LPL Financial’s (“LPL”) Strategic Wealth Management platform (“SWM II”). Description of Services The Program is an investment advisory program sponsored and managed by BFG. The Program provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. In addition to completing a Discretionary Asset Management Agreement with BFG, to join the program a person must: 1) Complete an investor profile that describes the client’s financial needs, investment objectives, time horizon, and risk tolerance, as well as any other factors relevant to the client’s specific financial situation (the Investor Profile) and any other supporting documentation required for the Program; 2) Complete a new account agreement with LPL for participation in the Program (Broker-Dealer); and 3) Open a securities brokerage account with LPL and deposit those client assets designated for participation in the Program (Program Assets) into the Account. After an analysis of any information provided by the client to BFG, the Firm shall assist the client in developing an appropriate investment strategy for the Program Assets in their Account. Thereafter, all clients are encouraged to discuss their needs, goals, and objectives with BFG and to keep BFG informed of any changes thereto. BFG shall contact clients at least annually to review its previous services and/or recommendations and to determine whether changes should be made to the clients’ Investment Strategy. Management of Your Portfolio All clients in the Program shall grant BFG discretionary authority to buy, sell, and otherwise trade for their Account and to liquidate previously purchased securities that the client has transferred to their Account. Program Assets in the client’s Account shall be managed by one of BFG’s IARs. In the event the client participates in the Program, BFG shall provide its investment management services and arrange for brokerage transactions under a single annual advisory fee for both advisory services and execution of transactions. Clients in the Program do not pay brokerage commissions, markups, or transaction charges for execution of transactions in addition to the advisory fee. The advisory fee is negotiable between the client and BFG and is set out in the advisory agreement. The advisory fee is a percentage based on the value of all assets in the account, including cash holdings. The advisory fee will vary among advisors in the Firm as each IAR has their own fee schedule for similar services. The advisory fee is paid to BFG and is shared between BFG and its associated persons (IARs). Clients should be aware that if a Client elects to participate in the Program based on a recommendation from BFG, BFG receives compensation as a result. This compensation includes the advisory fee and other compensation, such as bonuses, awards, or other things of value offered by LPL to BFG or its associated persons. The amount of this compensation may be more or less than what BFG would receive if the client participated in other LPL programs, programs of other investment advisors, or paid separately for investment advice, brokerage, and other 5 Bentley Financial Group, Inc. client services. Therefore, BFG has a financial incentive to recommend a Program account over other programs and services. The investment products available to be purchased in the Program can be purchased by clients outside of a Program account, through broker-dealers or other investment firms not affiliated with BFG. Fees for Participation in the Program Clients in the Program pay a single annualized fee for participation in the Program (the Program Fee). BFG shall charge an annual fee based upon a percentage of the market value of the assets being managed by BFG. The Firm’s annual fee shall be prorated and charged quarterly, in advance, based upon the market value of the assets being managed by BFG on the last day of the previous quarter. The annual fee shall vary (between 0.15% and 2.20%) depending upon the market value of the assets under management. BFG, in its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc.). Under the Program, clients receive both investment advisory services and the execution of transactions in securities for a single, combined annualized fee, the Program Fee. The cost of participation in the Program will vary from the cost of purchasing such services separately. The number of transactions made in the client’s Account, as well as the commissions charged for each transaction, will determine the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. The Program Fee may be higher or lower than fees charged by other sponsors of comparable investment advisory programs. In certain circumstances, Clients will incur charges imposed by third parties in addition to the Program Fee, such as fees charged by Independent Managers, custodial fees, charges imposed directly by a mutual fund or exchange traded fund in the account (which shall be disclosed in the fund’s prospectus, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees on brokerage accounts and securities transactions. When purchasing mutual fund shares for a Client’s account, a Client is subject to various fees and charges, including, but not limited to, the cost of portfolio management, creating account statements, account services, recordkeeping, commissions, and legal services. The fees and charges a Client will pay are generally determined by the share class that the Client purchases. Some share classes are subject to either a front-end sales charge or a deferred sales charge and may be appropriate when implementing a pure buy and hold strategy. Other share classes impose a higher ongoing fee (12b-1 fee) which is retained by the custodian. There are limitations on the availability of share classes to Clients based on service providers and the funds themselves. These limitations may be imposed by the custodian if, for example, the custodian’s platform only makes certain share classes available. The funds themselves impose certain limitations, such as minimum investment requirements. BFG seeks to use the lowest cost share class available while considering the Client’s investment time horizon and preference. BFG requires that pre-approval be obtained for any mutual

fund investments where the lowest cost expense ratio share class available is not used. On a quarterly basis, BFG reviews mutual fund holdings to identify any non-advisory share class holdings and to evaluate for share class exchange. For assets held outside of any wrap fee programs, clients will typically incur brokerage commissions and transaction fees. Such charges, fees and commissions are exclusive of and in addition to BFG’s fee. 6 Bentley Financial Group, Inc. Under the Program, transaction costs are borne by the adviser and are transaction based or asset based. If the transaction costs borne by the adviser are transaction based, the adviser has a conflict of interest because the adviser has a financial incentive to trade less frequently. In addition, because transaction charges vary by security type, there is a conflict of interest for the adviser because the adviser has an incentive to select securities for a Client’s accounts that cost the adviser less than other types of securities. If the adviser selects a $0 transaction charge security for the Client’s account, such as a No Transaction Fee fund (“NTF”), the security, including an NTF, tends to have a higher expense ratio, which is borne by the Client. In these cases, an additional conflict is created because the Client is in the Program paying a higher advisory fee while products purchased for the account have no transaction fee. Fees for Management During Partial Quarters of Service For the initial period of participation in the Program, the Program Fee shall be calculated on a pro rata basis. The Program Agreement between BFG and the client will continue in effect until terminated by either party pursuant to the terms of the Program Agreement. The Program Fee shall be prorated through the date of termination and any remaining balance shall be refunded to the client in a timely manner. Additions may be in cash or securities provided that BFG reserves the right to liquidate any transferred securities or decline to accept securities into a client’s account. BFG will consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred sales charge), and/or tax ramifications. If assets are deposited into or withdrawn from an account after the inception of a quarter, the Program Fee with respect to such assets will be prorated based on the number of days remaining in the quarter. Transaction and Share Class Fees Although clients do not pay a transaction charge for transactions in a SWM II account, clients should be aware that BFG pays LPL transaction charges for those transactions. The transaction charges paid by BFG vary based on the type of transaction (e.g., mutual fund, equity, or ETF) and for mutual funds based on whether the mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL. Transaction charges paid by the Advisor for equities and ETFs are $7. For mutual funds, the transaction charges range from $0 to $26.50. Because BFG pays the transaction charges in SWM II accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50. Clients should understand that the cost to Advisor of transaction charges may be a factor that BFG considers when deciding which securities to select and how frequently to place transactions in a SWM II account. In many instances, LPL makes available mutual funds in a SWM II account that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as Class I, institutional, investor, retail, service, administrative, or platform share classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund in SWM II in many cases will not be the least expensive share class that the mutual fund makes available and was selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through SWM II. In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay LPL a 12b-1 fee for providing shareholder services, distribution, and marketing expenses (“brokerage- related services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes, it is generally more expensive for a client to own Class A 7 Bentley Financial Group, Inc. Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time and keep more of his or her investment returns than an investor who holds Class A Shares of the same fund. BFG has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares are available. Although the client will not be charged a transaction charge for transactions, BFG pays LPL a per transaction charge for mutual fund purchases and sales in the account. BFG generally does not pay transaction charges for Class A Share mutual fund transactions accounts but generally does pay transaction charges for Platform Share mutual fund transactions. The cost of transaction charges generally may be a factor the Advisor considers when deciding which securities to select and whether to place transactions in the account. The lack of transaction charges to BFG for Class A Share purchases and sales, together with the fact that Platform Shares generally are less expensive for a client to own, presents a significant conflict of interest between BFG and the client. In short, it costs BFG less to recommend and select Class A share mutual funds than Platform shares, but Platform shares will generally outperform Class A mutual fund shares based on internal cost structure alone. Clients should understand this conflict and consider the additional indirect expenses borne because of the mutual fund fees when negotiating and discussing with your Advisor the advisory fee for management of an account. As noted above, to mitigate this conflict BFG seeks to use the lowest cost share class available while considering the Client’s investment time horizon and preference. BFG requires that pre-approval be obtained for any mutual fund investments where the lowest cost expense ratio share class available is not used, and on a quarterly basis, BFG reviews mutual fund holdings to identify any non-advisory share class holdings and to evaluate for share class exchange.