A. OWNERSHIP/ADVISORY HISTORY Action Point Financial Planning, LLC (“the Advisor”) DBA Fiduciary Financial Advisors was established as a Michigan Limited Liability Company in October 2014. It was subsequently registered as a Michigan investment advisor. It was then subsequently amended in January 2020 to include the DBA ‘Fiduciary Financial Advisors’ which the entity shall be referred to throughout the rest of this document. The Advisor’s current owner is Benjamin VerWys (“Mr. VerWys”). B. ADVISORY SERVICES OFFERED The Advisor’s services include portfolio management services, institutional retirement advisory service, partially outsourced CFO services, and the creation of financial plans for clients. The Advisor will meet with a client to evaluate the individual client’s investment needs, goals and objectives. After the evaluation, the Advisor may recommend one or several of the services described below. iv. FINANCIAL PLANNING The Advisor offers clients financial planning services to evaluate their financial situation, goals and risk tolerance. Through a series of personal interviews and the use of questionnaires the Advisor will collect pertinent data, identify goals, objectives, financial problems, potential solutions, prepare specific recommendations and implement recommendations. As a result of these actions, the Advisor’s advice may be provided on financial and cash management, risk management, financial issues relating to divorce or marital issues, estate planning, tax issues, stretch IRA planning, Investment Planning/Asset Allocation, retirement planning, educational funding, goal setting, or other needs as identified by the client and Advisor. The Advisor may offer broad-based planning services, or the client may desire advice on certain planning components; the Advisor can tailor services as desired by the client. At the conclusion of the Financial Planning Service the Advisor will present the client with the financial plan. ii. FIXED FEE FINANCIAL PLANNING The Advisor may provide financial planning services on a fixed fee basis. This service involves working one-on-one with an Advisor over an extended period of time by paying the annual fee on either a monthly, quarterly, or yearly, or hourly basis, as elected by the client. The client will have access to a planner who will work with them to design their plan. The planner will monitor the plan, recommend any changes and ensure the plan is up to date for the duration of the engagement. Upon desiring a comprehensive plan, a client will be taken through establishing their goals and values around money. The Advisor may charge for the creation of the plan and the requisite implementation. Financial planning engagements begin with the creation of a personalized plan that includes the establishment of goals and objectives. Financial planning services charged via a fixed fee may be broad- based or narrowly focused, depending on the client’s needs. For clients engaged in ongoing planning services (non-hourly Clients) the Advisor will proactively schedule and complete a periodic review of each personalized plan to make updates and adjust for life changes. Each client engaged in ongoing planning services receives scheduled communication to conduct periodic reviews of each client’s financial life. These reviews proactively seek to address the Client’s financial life and may cover a wide range of topics including but not limited to: Cash Flow and Debt Management Advisor will regularly review your income and expenses to determine your current surplus or deficit and advise on options for using surplus, or how to reduce expenses if they exceed your income. Advice may also be given on which debts to pay off in which order. Recommendations may be made regarding how to appropriate cash reserves for emergencies and other financial goals, plus strategies to save desired amounts. Risk Management A risk management review analyzes your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the potential cost of not. Employee Benefits We will provide feedback and analysis as to whether you are taking the full advantage of your employee benefit programs. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. Retirement Planning Retirement planning services typically include projections depicting the likelihood of achieving your financial goals, with financial independence usually the primary objective. For situations where projections show less than the desired results, a recommendation may include showing you the impact on those projections by making changes in certain variables (i.e., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. Tax Planning Strategies Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. Education Planning College funding advice may include analyzing how much will be needed to achieve successful education funding goals, along with savings strategies and the “pros-and-cons” of various college savings vehicles that are available. Investment Consultation Our investment consultation services may provide information on the types of investment vehicles available, employee retirement plans and/or stock options, investment analysis and strategies, asset selection and portfolio design, as well as assisting you with your investment account if it is maintained at another broker/dealer or custodian. Other than Scheduled Review We strongly urge our clients to notify us of any change in their circumstances, and to schedule a review any time there is such a change. An annual review will be conducted even in the event of no substantial change, because tax laws, estate laws, and investment vehicles are always changing. iii. PORTFOLIO MANAGEMENT The Advisor’s portfolio management engagement with a client will include, as appropriate, the following: ● Providing assistance in reviewing the client’s current investment portfolio against the client’s personal and financial circumstances as disclosed to the firm in response to a questionnaire and/or in discussions with the client and reviewed in meetings. ● Analyzing the client’s financial circumstances, investment holdings and strategy, and goals. ● Providing assistance in identifying a targeted asset allocation and portfolio design. ● Implementing and/or recommending an appropriate investment portfolio. ● Implementing changes in the client’s investment portfolio in consideration of changes in the client’s personal circumstances, investment objectives, and tolerance for risk, the performance record of any of the client’s investments, and/or the performance of any fund retained by the client, as well as based on changing economic and market outlooks. With non-discretionary portfolio management services, prior to the execution of any trades, the Advisor will telephone the client to receive his/her authorization. Upon receiving the client’s authorization, the Advisor will execute the trade per his/her instructions. iv. INSTITUTIONAL RETIREMENT INVESTMENT ADVISORY SERVICES The Advisor also provides investment consulting and investment advisory services to institutional ERISA and non-ERISA retirement plans. Institutional investment management services typically include portfolio design, preparation of investment policy statements, screening of investment selections, and performance monitoring. Employees in qualified retirement plans are protected by the Employee Retirement Income Security Act of 1974 (ERISA), which requires employers, investment advisors, and plan administrators to put employees’ interests first when managing retirement savings plans. Public retirement systems are governed by similar state laws and often incorporate the protections of ERISA. In order to demonstrate that a plan fiduciary has operated in a prudent manner, there are certain steps that the fiduciary must take. The Advisor is committed to helping fiduciaries understand their roles and to assist them in implementing a process that allows them to fulfill their duties and responsibilities. The Advisor will assist plan fiduciaries in the following: Investment Selection and Monitoring ● Creating an investment policy statement ● Screening investment selections ● Monitoring the investment options against well-defined risk and return criteria Plan Evaluation/Benchmarking The Advisor also “benchmarks” retirement plans against those of organizations in the same industry and against national “industry” data. Factors that are used to evaluate retirement plans include the following: ● Participation, deferral percentage, and asset allocation ● Investment performance ● Plan design ● Total plan costs ● Recordkeeping and administration ● Participant education and communication ● Technology ● Service provider capabilities and profiles Vendor Search and Plan Implementation The Advisor will also assist its retirement plan clients in selecting trustees, custodians, actuaries, and other service providers. This process involves: ● Generating criteria to identify appropriate service provides ● Developing requests for proposals ● Objectively rating service providers ● Evaluating highly rated service provider candidates Once a service provider is selected, the Advisor will assist a client in implementing the client’s retirement plan program. In implementing the program, the Advisor will, among other things, review the plan design, develop performance standards, and review the service provider’s contract. v. Participant Account Management (Discretionary) We use a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Employee Education The Advisor works with corporations to provide financial educational services to the company’s employees. The Advisor will provide on-site visits to companies to help their employees with their individual financial situations. The Advisor provide group seminars and individual meetings. The topics covered include but are not limited to budgeting, financial planning, risk tolerance, asset allocation, and retirement projections. This service may be provided in conjunction with the other listed service within section v. or as an individual service with a stand-alone fee. 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. v. OUTSOURCED CFO SERVICES For business owner and small business clients, the Advisor may provide a comprehensive service focusing on improving the financial aspects of the business. This program will be delivered on a consulting basis for a separate fee that will be charged on a fixed annual amount and will have its own agreement that the Client signs and acknowledges separate from the standard agreements that are used for investment management and financial planning services. Through this program, the Advisor may collaborate with the Client’s CPA, bookkeeper, or payroll manager. Additionally, when needed, the Advisor may provide some of these resources in the form of an outsourced, contracted specialist to deliver aspects of the program such as bookkeeping. The Advisor shall not provide bookkeeping services directly but may retain a third-party bookkeeper to facilitate this portion of the program. To be eligible to offer this service, any Individual Advisor Representatives of the Advisor must be certified as a Certified Exit Planning Advisor (CEPA) and have their certification in good standing with the Exit Planning Institute, which is the certifying organization OR partner with a CEPA certified team member for the implementation of the Outsourced CFO program. The amount of the annual fixed fee varies by client and scope of work. The fee may be as low as $7,200 and as up to no more than $50,000 per year. The services encompassed in the outsourced CFO service may include the following: ● Oversee financial strategy ● Selection and introduction to CPA, bookkeeper, payroll service, commercial insurer, or banker ● Review QuickBooks and bookkeeping logs and properly classify transactions ● Run forecasting and trend reporting for the Client or CPA ● Meet with company leadership to provide insight on reports and trends ● Cash management guidance ● Commercial lending guidance ● Identify and process checklist of best practices such as by-laws, policies and procedures, key man risk, buy/sell agreements, and operating agreements ● Help deliver financial vision and strategy to team, owners, and investors ● Provide guidance on succession planning and exit strategy vi. Professional Trustee Services Certain Individual Advisor Representatives of the firm are qualified to act as Professional Trustees at an Individual Trustee level. Neither the firm or any IAR’s shall act in the capacity of a Corporate Trustee. The IARs authorized to act as Individual Professional Trustees may offer comprehensive services related to the duties of a Trustee may include the following:
• Determination of eligible withdrawals in accordance with the written Trust document
• Collaboration with the Estate Planning Attorney regarding income withdrawal needs for the sake of Trust document creation, or modification
• Payment of bills and cashflow management
• Reconciliation of assets, liabilities, insurance policies, or annuities
• Execution of estate upon death
• Distribution of estate upon beneficiary attained age
• Oversight of tax return completion (third party CPA firm will actually execute the tax return) C. TAILORED SERVICES As described above, the Advisor’s services are individualized to each client. Portfolio management clients may impose restrictions on investment in

certain securities or types of securities. All restrictions must be presented to the Advisor in writing. D. WRAP PROGRAM The Advisor does not sponsor a wrap program. E. CLIENT ASSETS MANAGED As of December 31, 2023, Fiduciary Financial Advisors manages $ 555,420,848 in client assets of which $ 545,370,048 is discretionary and $ 10,050,800 is non-discretionary. 5. FEES AND COMPENSATION All clients will be required to execute a written agreement that will describe the type of services to be provided and the fees, among other items. FINANCIAL PLANNING Advisor may provide financial planning services on a fixed fee basis. The fixed fee for ongoing planning engagements may be paid either monthly, quarterly, or annually. Financial planning engagements begin with the creation of a personalized plan that includes the establishment of goals and objectives. Immediately upon delivery of the personalized plan, Advisor will begin ongoing monitoring and adhere to a series of tasks and ongoing work that is outlined accordingly in this agreement. Within the same calendar month of the creation of the personalized plan, the Advisor will assess an ongoing monthly fee ranging from $20 to $2,500, which is paid in advance each month going forward. For non-recurring engagements, the Advisor may charge either a one-time planning fee of up to $5,000 or provide non- recurring planning services for an hourly fee for which the maximum hourly fee is up to $350/hour. Hourly work will be accrued in 15-minute intervals. For one-time engagements, the amount will be determined on a case by case basis with the fee based on the complexity of the situation and the needs of the client. The fixed fee will be agreed upon before the start of any work. In the case of either one-time or hourly planning engagements, fees are due within 30 days of invoice. Payment is to be made via either a third-party processor such as AdvicePay or the client may be invoiced and remit payment via check or PayPal. Financial planning fees are negotiable and arrangements with any Client may differ from those described above. Fixed fee financial planning fees do not include any compensation that might be generated upon implementation of any investment advice. Fees will not be based upon a share of capital gains or capital appreciation of the funds or of any portion of the funds under advisory contract. This Agreement shall remain in effect until terminated by either party. A Client may terminate this service for any reason by giving seven (7) days written notice to the Advisor at Fiduciary Financial Advisors, 124 Fulton St East #200, Grand Rapids, MI 49503. In the event that a refund is required, a check will be sent back for the pro-rata portion due back to the client. PORTFOLIO MANAGEMENT SERVICES Assets Under Management based: Fees for portfolio management services may be billed a percentage of the assets under management. For clients whose accounts are held at Charles Schwab, or Fidelity, the fee will be calculated, accrued and due quarterly in arrears. For clients whose accounts are held at Assetmark or Hanlon, the fee will be calculated and due quarterly in advance. Assets Under Management Annual Fee Rate* Under $2,000,000 Up to 0.95% $2,000,000 to $5,000,000 Up to 0.90% $5,000,000 to $10,000,000 Up to 0.75% $10,000,000 to $50,000,000 Up to 0.50% $50,000,000 to $150,000,000 Up to 0.30% Over $150,000,000 Up to 0.15% * Fees are negotiable The fee is negotiable based upon the size of the account and/or if the client has multiple accounts within his household with the Advisor. The fee will be based upon the quarter end value of the account. The client will be asked to authorize the Advisor with the ability to withdraw the fee directly from the client’s account. The Advisor’s fees are separate and distinct from other fees or expenses that may include brokerage charges, transaction fees, and other related costs and expenses. Additionally, clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by mutual fund managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, as disclosed in a fund’s prospectus, which are separate and distinct from the firm’s fee. A client may terminate the Investment Management Agreement for any reason at any time and, within the first five (5) business days after signing the contract and receive a 100% refund of any fees paid without any cost or penalty. Thereafter, the Agreement may be terminated at any time by giving seven (7) days written notice. The written notice of termination must be sent to Fiduciary Financial Advisors, 124 Fulton St East #200, Grand Rapids, MI 49503. In the event of a refund, a check will be sent back for the pro-rata portion due back to the client. Net Worth based: Fees for portfolio management services may be billed as an annual fixed dollar fee based on the Client’s household net worth in accordance with the below fee schedule: Household Net Worth as determined by Client’s balance sheet Annual Fee Rate* Under $1,000,000 $7,500 $1,000,000 to $2,000,000 $12,000 $2,000,000 to $4,000,000 $18,000 $4,000,000 to $6,000,000 $28,000 $6,000,000 to $8,000,000 $35,000 $8,000,000 to $12,000,000 $40,000 $12,000,000 to $20,000,000 $45,000 Net worth above $20,000,000 Determine with Advisor * Fees are negotiable The fee is negotiable and may be higher or lower based on the complexity of the client and a variety of other factors. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian. Near the start of each year, clients will receive an invoice breaking down the fee for the upcoming year along with the formula used to calculate the fee. At the end of each year, the net worth will be re-evaluated to determine if a change in fee is necessary for the following year. In the event the fee level is scheduled to increase for any reason, the client will be notified via e-mail and provided the new fee amount. In the event the client does not respond or acknowledge within 30 days of notice, the Adviser will increase the fee as scheduled accordingly. Fees charged by Adviser may be negotiated and vary among clients for similar services. Remittance in the full amount of the management fees and brokerage fees and commissions shall be collected by the custodian of Client’s account by debiting Client’s accounts and liquidating securities selected by the Adviser, if necessary. Client authorizes and directs said custodian to pay to Adviser its allocable portion of the management fees. Fees will not be based upon a share of capital gains or capital appreciation of the funds or of any portion of the funds under advisory contract. The Advisor’s fees are separate and distinct from other fees or expenses that may include brokerage charges, transaction fees, and other related costs and expenses. Additionally, clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by mutual fund managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, as disclosed in a fund’s prospectus, which are separate and distinct from the firm’s fee. A client may terminate the Investment Management Agreement for any reason at any time and, within the first five (5) business days after signing the contract and receive a 100% refund of any fees paid without any cost or penalty. Thereafter, the Agreement may be terminated at any time by giving seven (7) days written notice. The written notice of termination must be sent to Fiduciary Financial Advisors, 124 Fulton St East #200, Grand Rapids, MI 49503. In the event of a refund, a check will be sent back for the pro-rata portion due back to the client. For clients whose accounts are held at Assetmark, the calculation and refund process is handled directly by the custodian in accordance with Assetmark’s ‘fee billing process’ which can be found in the ‘Fees and Compensation of their ADV located here: https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=726090 For clients whose accounts are held at Hanlon, the calculation and refund process is handled directly by the custodian in accordance with Hanlon’s fee billing process which can be found in the ‘Fees and Compensation of their ADV located here: https://files.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=718954 INSTITUTIONAL RETIREMENT ADVISORY SERVICES The firm’s fees for its institutional retirement advisory services to retirement plan sponsors may be paid by the plan or trust or by the plan sponsor and may be a flat fee or a fee that is a percentage of the assets in the plan. Non-Discretionary Asset-Based Fee Alternative Fees for institutional asset management are generally calculated based on a percentage of client assets under advisement and are calculated quarterly in arrears according to the following schedule: Assets Under Advisement Annual Fee Rate* Under $2,000,000 Up to 0.95% $2,000,000 to $5,000,000 Up to 0.85% $5,000,000 to $10,000,000 Up to 0.70% $10,000,000 to $50,000,000 Up to 0.55% Over $50,000,000 Up to 0.30% * Fees are negotiable. Fees may be paid monthly or quarterly in advance or arrears, as negotiated by the Advisor and the client. Fees that are a percentage of the plan’s assets are based on the value of the aggregate assets as of the end of the preceding period for which the fee is being calculated. The plan will select either direct fee withdrawal from the plan assets or to have the fee invoiced. Fixed-Fee Alternative The amount of the fee is negotiable and is generally determined by the size of the account, the diversification desired in the portfolio, the scope of services agreed to by the client, and the number of meetings and consultations expected. A flat fee is generally between $2,500 and $100,000. Typical services include: ● Creating an investment policy statement ● Monitoring the investment options against well-defined risk and return criteria ● Selecting investment managers An agreement for institutional retirement advisory services may be terminated upon 30 days’ notice to the firm. If the client has not received the firm’s disclosure documents (Brochure and Brochure Supplements) at least 48 hours prior to signing the investment advisory agreement, the client has the right to terminate an agreement without penalty within five business days after entering into the agreement. Any earned, unpaid fees will be immediately due and payable. Any unearned, prepaid fees for the month or quarter will be promptly refunded based upon the termination date in the month or quarter. For example, if a client terminates 15 days into a 30 day month, the client will receive a 50% refund of prepaid fees (15/30 = 50%). For clients paying on a quarterly basis in advance, should the client terminate 30 days into a 90- day quarter, the client will receive a 67% refund of fees. (30/90 = 33%; 100% - 33% = 67%). EMPLOYEE EDUCATION SERVICES The Advisor may charge a separate annual fixed fee for employee education services. The fixed fee ranges from $2,500 to $50,000. The fee is negotiable, and it is based upon the scope of work. The fee is billed quarterly in arrears. An invoice will be sent to the company that is due within 15 days of receipt. A client may terminate the corporate employee retirement education services for any reason at any time and, within the first five (5) business days after signing the contract and receive a 100% refund of any fees paid without any cost or penalty. Thereafter, the Agreement may be terminated at any time by giving seven (7) days written notice. OUTSOURCED CFO SERVICES The fee for this service may have an up-front onetime fee of $2,500.00 which covers the launch of the program and the gathering of the relevant data and organizing of it. After paying the up-front fee, the program has a flat fee billed monthly in arears of $950/month. This fee is negotiable and may vary client to client based on the level of complexity and scope of work involved. Invoices will be sent monthly and may be paid via a third-party billing program such as AdvicePay or PayPal. A client may terminate the outsourced CFO service for any reason at any time and, within the first five (5) business days after signing the agreement and receive a 100% refund of any fees paid without any cost or penalty. Thereafter, the Agreement may be terminated at any time by giving seven (7) days written notice. The written notice of termination must be sent to Fiduciary Financial Advisors, 124 Fulton St East #200, Grand Rapids, MI 49503. In the event of a refund, a check will be sent back for the pro-rata portion due back to the client. PROFESSIONAL TRUSTEE SERVICES Trustee Services have an applicable annualized billing rate for the periodic fees which can be found on the Trustee Services agreement. The fee will be calculated and accrued in arrears. In an account that is billed monthly with a period ending account value of $3,000,000 at an annual rate of 0.45%, the account will be charged the pro-rated portion of the annual, thus a $3,000,000 account would have a deduction for the month of $1,125.00 which is calculated as $3,000,000 x 0.45% = $13,500/12 months = $1,125.00. Similarly, in an account with quarterly billing, the calculation is done in arrears and pro-rated for fund flows. Thus, if the same $3,000,000 value account is billed quarterly, the fee would result in a $3,375.00 fee which is calculated as follows: $3,000,000 x 0.45% = $13,500/4 quarters = $3,375.00. When an Advisor or Individual at Fiduciary Financial Advisors is retained as an Individual Professional Trustee, the following fee schedule applies: Marketable Securities Maximum Annual Rate* Minimum annual fee $10,000 Less than $5,000,000 Up to 0.45% $5,000,001 to $10,000,000 Up to 0.40% $10,000,001 to $20,000,000 Up to 0.35% $20,000,001 to $50,000,000 Up to 0.30% Over $50,000,000 Up to 0.25% * Fees are negotiable The fee for this service based on the amount of the marketable securities held by the Trust and must comply with the maximum fee schedule laid out in Trustee Services fee schedule above. The fee will be charged in arrears on a pro-rated basis in accordance with the fee listed in each Client’s signed Trustee Services agreement. A client may terminate the Trustee service for any reason at any time and, within the first five (5) business days after signing the agreement and receive a 100% refund of any fees paid without any cost or penalty. Thereafter, the Agreement may be terminated at any time by giving seven (7) days written notice. The written notice of termination must be sent to Fiduciary Financial Advisors, 124 Fulton St East #200, Grand Rapids, MI 49503. In the event of a refund, a check will be sent back for the pro-rata portion due back to the client. ADDITIONAL FEES AND SERVICES Persons providing investment advice on behalf of our firm may also be licensed as independent insurance agents. These personas will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions. You are under no obligation, contractually or otherwise, to purchase insurance products through any personal affiliated with our firm.