Advisory Solutions Wrap Fee Program. Park Place Capital Corporation (the “Firm” or "we") offers the Advisory Solutions Wrap Fee Program (“Program”) whereby the Firm manages Client accounts for a single fee that includes portfolio management services, custodial services and the transaction/commission costs. Under this Program, customers have the option to obtain investment advice either on a discretionary or non-discretionary basis in a manner designed to assist Clients in obtaining professional asset management for a convenient single “Wrap Fee.” As the portfolio manager, we are responsible for the research, security selection and implementation of transaction orders in the Client’s account or for the selection of sub-advisor “money managers” who conduct research, security selection and implementation of transaction orders. The terms and conditions under which a Client participates in the Program will be set forth in a written agreement between the Client and the Firm. The overall cost incurred from participation in our Program may be higher or lower than if the services were purchased separately. Once a Client has established their investment objectives, goals, risk tolerance, and an overall asset allocation, we will assist the Client in selecting suitable allocations of assets among various securities (each such allocation, a "Portfolio") from those available in the Program. Each Client should carefully review each proposed Portfolio to understand the types of investments the Portfolio will make as well as the risks related to each such Portfolio prior to investing in any Portfolio. We have entered into one or more agreements with one or more third party advisers (collectively, "Sub-Advisers") pursuant to which the Sub-Advisers make their Portfolios available to our Clients in one of two ways: a Portfolio may be traded directly by the Sub-Adviser (in such case, a “Manager-Traded Portfolio”), or we may retain trading responsibility over accounts in the Portfolio (in such case, a “Model-Based Traded (“MBT”) Portfolio”). Manager-Traded Portfolios. The Sub-Adviser for a Manager-Traded Portfolio assumes full discretionary portfolio management responsibilities over each Client account invested in the Portfolio (in that capacity, the third party adviser will be referred to as a “Portfolio Manager”), including determining the securities to be bought or sold, implementing those decisions for the invested accounts, and for all other aspects of portfolio management for the accounts. The Portfolio Manager may implement trades through any broker-dealer, subject to the Portfolio Manager's obligation to provide best execution in light of all applicable circumstances. MBT Portfolios. Alternatively, if you select an MBT Portfolio, the Sub-Adviser will provide us with its model Portfolio and ongoing updates, and we will be responsible for implementing those transactions (in such capacity, the Sub-Adviser will be referred to as a “Model Adviser”). Therefore, with respect to MBT Portfolios in the Program, we will retain discretionary trading authority over Client accounts and will be considered the "Portfolio Manager". Program Fee. Under the Program, our advisory services (including portfolio management or advice regarding selecting sub-adviser money managers) and transaction services are provided for one fee. The essential difference between transactional accounts and those under management in a wrap-fee program is the way in which transaction services are paid. The Program fee is a percentage of the assets under management, with the specific percentage to be negotiated on an individual Client basis. The Program fee will not exceed an annual fee of 1.35% of assets under management. The Program fee is negotiable based on the type of client, the complexity of the client’s situation, the composition of the client’s account, the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. Our annual Program fee may be higher than that charged by other investment advisers offering similar services/programs. The exact Program fee to be charged is disclosed in the client agreement that must be signed by both you and us before any services are provided. The Program Fee is billed in advance on a quarterly basis. The effective date of the fee will be the first day of the quarter during which the client agreement was signed. The initial Program Fee will be prorated to cover the period from the date the Client account is opened and approved, through the end of the then current full calendar quarter. For purposes of calculating the initial and subsequent Program Fee, the account’s value includes the sum of the long market value of all securities

(less margin debit balances), money market, and cash. No fee adjustment will be made for partial withdrawals or for appreciation or depreciation of the account within a quarterly billing period. In accordance with the terms of the individual Agreement, a pro-rata refund of fees charges will be made to Client if the Account is closed within a quarterly billing period. We may modify the Program fee upon prior written notice to the Client. If the Client does not agree to the modified fee calculation, the Client may elect to terminate the advisory relationship. Program fees are generally deducted from your account although you can also request that they be billed directly to you. If fees are deducted from your account, you must authorize the qualified custodian to deduct fees from your account and pay the fees directly to us. If you choose to have fees billed directly to you, they are due upon receiving our billing notice. The billing notice details the formula used to calculate the fee, the assets under management and the time period covered. Fees for the services of our firm are due immediately after your receipt of the billing notice. Other Fees and Charges. In addition to the Program fee, Clients may also incur certain charges imposed by third parties. Such charges may include, but are not limited to: charges imposed directly by a mutual fund, index fund, or exchange traded fund purchased for the account which shall be disclosed in the fund’s prospectus (e.g., fund advisory fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, exchange and floor fees, and other fees and taxes on brokerage accounts and securities transactions ("Ancillary Fees"). The Firm may be entitled to a portion of these Ancillary Fees, which creates a conflict of interest that gives Adviser an incentive to recommend such investments be made in the Account. Comparable Services; Potential Conflict of Interest. We believe our fees for advisory services are reasonable with respect to the services provided and the fees charged by other investment advisors offering similar services. However, lower fees for comparable services may be available from other sources. The Program may cost the Client more or less than purchasing such services separately. For example, if an account is not subject to a wrap fee and pays individual brokerage costs (a "Non-Wrap Fee Account"), the Non-Wrap Fee Account may incur additional expenses if numerous securities transactions are executed. Conversely, the Program Fee may be higher than the overall fees in a Non-Wrap Fee Account if there are very few securities transactions within an account. We will receive a portion of the Program fee as described above, and the amount of our portion of the Program fee may be more than what we would receive if the Client participated in a Non-Wrap Fee Account. Therefore, may have a financial incentive to recommend the Program over other programs or services. Fees for Referral Activities. The Firm receives fees based on the referral of clients to other registered investment advisers. A referral generally occurs if a client desires or needs to pursue an investment strategy that is not offered by the Firm. The referral fees are generally 25% of the advisory fee received by the third party adviser, and are paid on a recurring basis over the life of the relationship when the third party adviser receives its advisory fee for managing the referred account. Other Conflicts of Interest. In addition to the compensation for investment services described above, we are also compensated for providing other financial services as described in Item 9. Our charges for investment services and for other financial services will include a reasonable profit for the Firm, our affiliates, and our representatives. This profit incentive creates a conflict of interest that could influence us to recommend opening or maintaining accounts that may have higher costs or less favorable services than other suitable alternatives which do not provide equivalent compensation to the Firm, our affiliates, or our representatives. The Firm has established various policies and processes to address these conflicts of interest, including the following:
• Disclosure to our clients of the fees described above and our affiliations described in Item 9;
• Waiver of the Firm's Management Fees otherwise due with respect to the Monteagle Fund when clients invest in such Fund, although not the Operating Fees or any Management Fees where the portfolio is sub-advised by unaffiliated money managers;
• Suitability review process at the time each account is established; and
• Periodic account reviews after an account is established.