A. CFC sponsors a “Wrap Fee” program whereby CFC will provide the services described in this brochure for a single fee rather than having clients pay separate fees for advisory services, trade execution, custody, other standard brokerage services, and investment management services. B. CFC provides financial planning, investment advice, and investment supervisory services. Advice to clients includes financial planning, cash flow planning, tax planning, debt management, portfolio analysis, retirement planning, insurance analyses, business planning, pension design, education planning, estate planning, charitable gifting techniques, and investment counseling to individuals, businesses and personal trusts. CFC provides tax return preparation, bookkeeping, accounting bill paying services, and business planning to clients as additional ancillary services in support of its primary financial planning and investment supervisory services. C. Financial planning and investment management are tailored to the needs of individual clients and may be comprised of several client consultations which focus on a detailed analysis of the overall financial position of a client, including cash flow, taxes, debt, risk management, estate planning, retirement planning, and investment analysis. Recommendations are made in writing or verbally. CFC does allow clients to impose certain restrictions on investing in certain securities or types of securities if the client does so when completing their investor profile and/or account instructions or in writing at a subsequent time. D. The recommendations are of a general nature and may include recommendations concerning insurance or investing or not investing in various types of securities such as money market funds, government securities, stocks, bonds, mutual funds, and various limited partnership programs, as well as certificates of deposit. Security analysis methods include charting, fundamental, technical, and cyclical, and sources of information may include financial newspapers and magazines, research materials prepared by others, corporate rating services, annual reports, prospectuses or filings with the SEC and company press releases. Investment strategies used to implement any investment advice may include long term purchases (securities held more than one year), short- term purchases (securities sold within a year), trading (securities sold within 30 days), short sales, margin transactions, option writing including covered and uncovered options, or spreading strategies. CFC offers advice on domestic and foreign equity securities, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, variable life insurance, variable annuities, mutual fund shares, U.S. government securities, options contracts on securities and commodities, futures contracts on tangibles and intangibles, and interests in limited partnerships. E. There are no differences in how CFC manages wrap fee accounts and how CFC manages other accounts. F. CFC does not maintain custody of your assets that we manage (although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15 Custody in the CFC ADV Disclosure Brochure). G. Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab) a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. Schwab is an independent SEC-registered broker-dealer. We are independently owned and operated and not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and open your account with Schwab by entering into an account agreement directly with them. We do not open an account for you. Not all advisors recommend their clients use a broker-dealer or other custodian selected by the advisor. CFC’s receipt of general platform services does not diminish CFC’s duty to act in the best interest of its clients, including seeking best execution of trades for client accounts. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account. H. For its Wrap Fee program CFC is compensated for its services through fees that are based on either a percentage of capital at work plus income, a percentage of assets under supervision, a flat fee, an hourly rate, or a combination of these methods. The fee will be based on the needs of the client, the complexity of each financial situation, and the complexity and size of the investment portfolio. The fees for ongoing service are specified in the Financial Advisory Contract (FA), the Asset Management Contract (IA), Flat Fee Contract (FF), or the Hourly Consulting Agreement (HA) delivered to the client and signed by the client. There is no minimum fee for these services. Fees are normally either debited from an approved money market account or paid by check. CFC provides clients with an invoice showing the amount of each fee. Other methods of fee payment may be accepted. The following fee schedules apply to CFC’s Wrap Fee program: COMPREHENSIVE FINANCIAL PLANNING FEES (FA) Dollar Amount of “Gross Income” and “Capital

at Work” Percentage Fee First $1,000,000 1.00% Next $2,000,000 0.75% Remaining balance greater than $3,000,000 0.50% A deposit of $500 is received upon execution and at each anniversary of the financial planning contract and the balance is due upon completion of the comprehensive plan ASSET MANAGEMENT FEES (IA) Dollar Amount of Investable Assets (IA) Percentage Fee First $1,000,000 1.00% Next $2,000,000 0.75% Remaining balance greater than $3,000,000 0.50% Ongoing fees will be assessed quarterly in arrears FLAT FEE (FF): The Flat Fee charged for planning and related services will vary depending on the complexity of the client’s financial situation and the planning services to be provided. A deposit of $500 is received upon execution and at each anniversary of the financial planning contract and the balance is due upon completion of the project. This fee is negotiated and agreed to prior to the commencement of the engagement. HOURLY FINANCIAL CONSULTING (HA): The Hourly Rate for financial consulting and planning services is $425.00. Hourly Consulting clients are provided an invoice detailing the services provided and the calculation of the amount due. Payment for ongoing Asset Management services is collected quarterly. Regular payment of the ongoing quarterly fee is required to maintain uninterrupted services under the applicable agreement. Payment for Comprehensive Financial Planning, Hourly Consulting and/or Flat Fee Financial Planning services are typically due upon completion of the planning services but may be collected in installments over a period of time as negotiated by the client and indicated in their contract. As a courtesy to existing clients who may have entered into agreements with the firm under previous fee schedules, and to accommodate clients with unique circumstances, fees may be based on different hourly rates or otherwise negotiated. Fees based on assets for certain clients may be negotiated based on service requirements and complexity. All fees received are kept by CFC and not shared with any other party. Methods of payment other than specified may be negotiated. All fees are made payable to, “Capitol Financial Consultants, Inc.” I. Wrap fee accounts, further described in the CFC Wrap Fee Brochure, are subject to the same fee schedule as non-wrap fee accounts. As such there are no additional fees for a wrap fee account as opposed to a non-wrap fee account. In order to evaluate whether a wrap fee account is appropriate for you, you should compare the agreed upon wrap fee program with the amounts that would be charged by other advisers, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under our Wrap Fee Program. If you choose to enter into the CFC wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services elsewhere. J. Conflict of Interest: When managing a client’s account on a wrap fee basis, CFC receives as compensation for our investment advisory services, the balance of the total wrap fee you pay after custodial, trading and other management costs (including execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your account(s) subject to a wrap fee. For example, our wrap fee arrangement creates incentives for our advisers to trade less frequently or select investments that reduce our costs, and in some cases increase expenses that are borne by the client. We are available to discuss execution- related pricing with you for any custodian we use to hold your assets so that you can compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. K. CFC does not participate in management fees or custodian fees charged by mutual funds, retirement plan custodians, or nonaffiliated investment managers, and such fees are separate from fees described under the Agreement. L. CFC’s fees are inclusive of securities brokerage commissions and transaction fees which may be incurred by the client. These fees, when combined with the other fees described in this Brochure, may cost you more or less than purchasing the various services described separately and/or based on the amount of trading in your account. M. Clients may incur certain charges imposed by custodians, brokers, third party investment managers and other third parties such as custodial fees, deferred sales charges, odd lot differentials, transfer taxes, wire transfer and electronic fund transfer fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in each fund’s prospectus and delivered to the client by the custodian. Such charges, fees and commissions are exclusive of and in addition to CFC fees and are discussed in the documents provided you by the custodian. N. Since, in some cases, the cost to provide the brokerage, transaction and related services may be less than the portion of the Wrap Fee assessed by CFC. CFC may therefore have an incentive to recommend its Wrap Fee account to you and you should evaluate your ability to obtain these services in a different manner.