Description of Services and Fees We are a registered investment adviser based in Smithfield, Rhode Island. We are organized as a corporation under the laws of the State of Rhode Island and we have been providing investment advisory services since 1994. Arthur C. Everly, Kevin R. Worthley, and Scott G. Everly are our principal owners. Currently, we offer Portfolio Management Services through the Custom Account Program, the Schwab Institutional Intelligent PortfoliosTM Program and through a third-party adviser, SEI Investment Management Corporation, as well as financial planning services, 529 College Savings Plan Asset Allocation Services, 401(k) Plan Advisory Services and seminars. We are also registered as an insurance agency in the State of Rhode Island and Massachusetts. The following paragraphs describe our fees and services. Please refer to the description of each investment advisory service listed below for information on how we tailor advisory services to your individual needs. You may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our officers, employees, and all individuals providing investment advice on behalf of our Firm. Financial Planning Services We offer broad-based, modular, and consultative financial planning services. Financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain us for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we review and analyze the information you provide to us, we will deliver a written and/or online plan to you, designed to help you achieve your stated financial goals and objectives. If you require advice on a single aspect of the management of your financial resources, we offer financial plans in a modular format and/or general consulting services that address only those specific areas of concern. These areas may include, but are not limited to, retirement planning, education planning, insurance and risk management, income tax planning, business planning, portfolio review and asset allocation, and/or financial decision making/negotiation. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify us if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan with us or use any of the other financial services or products we offer. Moreover, you may act on our recommendations through any other brokerage firm, investment advisor, or provider of investment or insurance products, or other financial services. We are compensated by either an hourly rate of $200 or by a fixed fee, which generally ranges between $250 and $3,000. The type and amount of the fees charged to you, subject to negotiation, will be based on your financial situation and the services requested. An estimate of the total cost will be determined at the start of the advisory relationship. The final fee shall be directly dependent upon the facts and circumstances of your financial situation and the complexity of the financial plan or service(s) requested. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you and may request that you pay an additional fee. We will require that you pay an initial retainer equal to one-half of the estimated financial planning fees in advance of any services rendered. The remaining balance shall be due and payable upon completion of the contracted services. Under no circumstances will we require prepayment of a fee more than six months in advance or in excess of $1,200. We may, in our discretion; offset up to one-half of the financial planning fees should you choose to implement the investment management recommendations through us. We reserve the right to determine whether the financial planning fees will be offset by the fees and/or commissions earned in the implementation process. Where we determine that we will offset fees, the scope and complexity of the financial planning services that were provided will determine the offset of the fee. Upon the initial presentation of a written financial plan to you, our objective is that you are satisfied with the plan as it is delivered. However, it may be the case that you are not satisfied with the plan upon initial presentation and, under this circumstance, we will amend the plan as needed at no additional charge to you. You may terminate the financial planning agreement by providing written notice. You will incur a pro rata charge for services rendered prior to the termination of the agreement. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Portfolio Management Services Custom Account Program We offer discretionary portfolio management services using our Custom Account Program ("Custom Account") whereby our investment advice is tailored to meet your needs and investment objectives. If you retain our portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables us to give you continuous and focused investment advice and to make investments on your behalf. As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may also invest your assets according to one or more model portfolios we have developed. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. In the Custom Account, we invest your assets in mutual funds and or exchange-traded funds (ETFs) only and such portfolios are comprised of a mix of asset classes which may be based on one or more model portfolios. However, you may wish to transact in other types of securities, such as equities and fixed-income securities, through this account. Under this circumstance, we will invest in these types of securities only upon specific direction from you. Moreover, choosing to purchase/sell these types of securities in the Custom Account may cause the portfolio's percentage weightings in certain assets classes to be over- or under-weighted. As a result, you may be exposed to more (or less) risk and may experience larger (or smaller) performance returns in your account. If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign, a limited power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing us with your restrictions and guidelines in writing. For accounts under $50,000 in value, we may recommend one of our Custom ETF model portfolios. These models are designed to achieve the client’s stated investment objectives but with less-expensive ETF investments and more flexibility in rebalancing strategies. Other than the investment components of these models, all other aspects of the Custom Account Program remain the same. Our fee for portfolio management services is based on a percentage of your assets we manage and is set forth in the following fee schedule: Assets Under Management Maximum Annualized Fee** Assets less than or equal to $500,000 1.00% Next $1,000,000 0.67% Over $1,500,000 0.33% Institutional Intelligent Portfolios TM Program We also provide portfolio management services through Institutional Intelligent Portfolios TM , an automated, online investment management platform for use by independent investment advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the "Program" and "SWIA," respectively). Through the Program, we offer clients a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange traded funds (ETFs") and a cash allocation. The client may instruct us to exclude up to three ETFs from their portfolio. The client's portfolio is held in a brokerage account opened by the client at SWIA's affiliate, Charles Schwab & Co., Inc. ("CS&Co"). We are independent of and not owned by, affiliated with, or sponsored or supervised by SWIA, CS&Co or their affiliates (together, "Schwab"). The Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios TM Disclosure Brochure (the "Program Disclosure Brochure"), which is delivered to clients by SWIA during the online enrollment process. We, and not Schwab, are the client's investment advisor and primary point of contact with respect to the Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the client's investment needs and goals, and managing that portfolio on an ongoing basis. SWIA's role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure. We have contracted with SWIA to provide us with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system that automates certain key parts of our investment process (the "System"). The System includes an online questionnaire that helps us determine the client's investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the System in response to the client's answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The System also includes an automated investment engine through which we manage the client's portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We do not receive a portion of a wrap fee for our services to clients through the Program. Clients do not pay fees to SWIA in connection with the Program, but we charge clients an annual fee of 0.50% per year. Our Program fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co as part of the Program. Schwab does receive other revenues in connection with the Program, as described in the Program Disclosure Brochure. We do not pay SWIA fees for its services in the Program so long as we maintain $100 million in client assets in accounts at CS&Co that are not enrolled in the Program. If we do not meet this condition, then we pay SWIA an annual fee of 0.10% (10 basis points) on the value of our clients' assets in the Program. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with CS&Co. For both the Custom Account and the Institutional Intelligent Portfolios TM Programs, our annual portfolio management fee is calculated and deducted from your account prorated quarterly in arrears based on the value of your account on the last day of the quarter. Clients who prefer to be billed directly for their management fees may submit a written request for this service. For these clients we generate and mail your bill on the same schedule. The fee schedules listed above reflect the fees charged for the management of the assets held in your account. This fee does not include any transaction charges or other fees imposed by the account's custodian, or any of the expense charges by the mutual funds or the ETFs purchased for your account. Upon your request, we will provide a fee schedule that provides more information on the transaction charges and maintenance fees (if any) imposed by the account custodian. Fund expenses are fully disclosed in the prospectus for the fund provided to you by the custodian. We do not charge advisory fees for individual common stock, individual bonds or other such securities held in a client's account at their direction. If you execute a portfolio management agreement at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which your account is funded. If you withdraw more than 20% of the account balance from your account prior to the end of the calendar quarter, we will be entitled to pro-rata fees on such withdrawal. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in you paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. The qualified custodian holding your funds and securities will debit your account directly for the advisory fees. Where your account is debited directly for the advisory fee, you will provide written authorization permitting the fees to be paid directly from your account held by the qualified custodian. We will not have access to your funds for payment of fees without your consent in writing. Further, the qualified custodian agrees to deliver at least a quarterly account statement directly to you. You are encouraged to review your account statements for accuracy. You may terminate the investment advisory agreement upon 30 days written notice. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. SEI Asset Management Program We also offer the SEI Asset Management Program (the "Program") to clients. The SEI Asset Management Program is a program whereby an independent investment adviser can make the SEI family of mutual funds available to clients. SEI is not an investment adviser in this instance and does not have the investment adviser relationship with you. The Program is designed as follows:
• First, we will determine your risk profile and investment objectives. We will help you set appropriate investment objectives as well as to determine your investment time horizon and risk profile.
• Next, we will set a relevant asset allocation policy for you. With our assistance, you will choose one of many mutual fund asset allocation models made available through the Program.
• Diversify among asset classes and styles. SEI selects the investment managers of the underlying mutual funds. SEI utilizes institutional investment management firms. The managers are monitored by SEI to ensure that their investment styles and performance remain consistent with the objectives of the mutual funds.
• We will supervise the account and take action in the account using our discretionary authority where we deem appropriate. Such action will be based upon recommendations provided by SEI based on the asset allocation model you chose.
• SEI Trust Company (a subsidiary of SEI Investments Company) acts as the transfer agent and custodian for your account. SEI Trust Company provides reporting services including consolidated monthly or quarterly statements (as selected by you), quarterly performance reports, and year-end tax reports. We charge an investment advisory fee as stated below. SEI charges an expense ratio to the fund; all expense ratios are disclosed in the prospectuses of the funds. SEI Private Trust Company, a subsidiary of SEI Investments Co. acts as the transfer agent and custodian for your account. SEI Private Trust Company, on our behalf and your behalf, debits the advisory fee from your account. SEI does not participate in the advisory fee. SEI Private Trust Company then forwards the fee to us. Market Value Breakpoint Maximum Annualized Fee Assets less than or equal to $500,000 1.00% Next $1,000,000 0.67% Over $1,500,000 0.33% SEI Trust Company will calculate and debit your account on a quarterly basis for the above- mentioned fees and charges. The charges to the account will be on an arrears basis and will be remitted quarterly net of any

applicable account and performance reporting charges not charged to you. Upon written notification, either party may terminate the agreement. Prorated fees will be charged based on market value on the date notice is received. You sign an advisory contract with us and account opening documentation with SEI. We provide our Firm Brochure to you and SEI provides a prospectus for the mutual funds utilized in the fee- based account. As custodian, SEI Private Trust Company provides all reporting functions for the account and supplies you with a statement on at least a quarterly basis. SEI does not act in the capacity of an investment adviser to you and therefore does not provide a solicitor's agreement, or their Brochure. The fee schedule that we charge for our advisory services in connection with the SEI Asset Management Program is included herein and in the SEI Advisory Agreement for client disclosure. SEI Managed Account Program We participate in the SEI Managed Accounts Program (the "Program"). To participate in the Program, we, SEI Investments Management Corporation ("SIMC") and you execute a tri-party agreement ("Managed Account Agreement") providing for the management of certain assets in accordance with the terms thereof. Pursuant to a Managed Account Agreement, you appoint us as your investment adviser to assist you in selecting an asset allocation strategy, which includes the percentage of assets allocated to designated portfolios of separate securities (each, a "Managed Account Portfolio") and may include the percentage of assets allocated to a portfolio of mutual funds advised by SIMC or an affiliate of SIMC. You appoint SIMC to manage the assets in each Managed Account Portfolio in accordance with an agreed upon strategy. SIMC may delegate its responsibility for selecting particular securities to one or more portfolio managers. The fees payable to us are as follows: Assets Under Management Maximum Annualized Fee Assets less than or equal to $500,000 1.00% Next $1,000,000 0.67% Over $1,500,000 0.33% SIMC may impose minimum account balances ranging from $50,000 to $1,000,000 depending upon the Managed Account Portfolio chosen and whether you select the tax management feature. Advisory fees charged by SIMC are separate and apart from our advisory fees. Assets managed by SIMC will be included in calculating our advisory fee. Advisory fees that you pay to the SIMC are established and payable in accordance with the brochure provided by SIMC. These fees may or may not be negotiable. You should review SIMC's brochure and take into consideration SIMC's fees along with our fees to determine the total amount of fees associated with this program. Under this Program, you receive investment advisory services, the execution of securities brokerage transactions, custody services and reporting services for a single specified fee. Participation in the Program may cost you more or less than purchasing such services separately. Additionally, the Program offers a feature called Integrated Managed Accounts ("IMAP"), which is an enhancement to the standard Program. In IMAP, SIMC selects one sub-adviser to serve as a tax manager for the entire Managed Account Portfolio. Other sub-advisers recommend securities using buy/sell lists for their specific asset class to which you have selected. An integration fee will be charged to your account when you select the IMAP feature. The fee will cover the integration of the equity managers, which helps result in increased coordination across the equity account, increased tax efficiency and additional features such as wash sale prevention. These additional fees only apply to the equity portion of your account that is allocated to the integrated equities portfolio; the fees do not apply to the fixed income or funds portion of your account (if applicable). A selection of your assets may receive a fee discount. 529 College Savings Plan Asset Allocation Services We offer discretionary asset allocation services to 529 College Savings Plans whereby our investment advice is tailored to meet your needs and investment objectives. If you retain our 529 College Savings Plan Asset Allocation services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will assist you in setting up a 529 Plan Account. With respect to this account, we will use the suitability information we gather to develop a strategy that enables us to give you asset allocation advice and to make investments on your behalf. Once we construct an investment portfolio for you, we will review your 529 Plan holdings on at least an annual basis and will rebalance the holdings as required by changes in market conditions, your financial circumstances, and the circumstances of the account's named beneficiary with regard to the proximity of requiring distributions for qualified expenses, (e.g., qualified educational expenses in the near future). If you participate in our discretionary asset allocation services, we require you to grant us discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with us, a limited power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing us with your restrictions and guidelines in writing. Our fee for the Services provided is an initial set-up fee of $150 when the account is opened. In the following calendar year and annually thereafter, an investment advisory fee of $150 per year will be billed to you for our continued services. The annual advisory fee shall be billed directly to the owner listed on the account and shall be payable to Wealth Management Resources, Inc. within 30 days of receipt. Our advisory fee is negotiable, depending on individual client circumstances. This fee does not include any transaction charges or other fees imposed by the plan’s sponsor, or any of the expense charges by the municipal fund securities purchased for your account. For clients who already have a relationship with us, we may, at our discretion, waive our normal fees for advising on these accounts in respect of this established relationship. Fund expenses are fully disclosed in the Program Description for the 529 College Savings Plan provided to you by us. Statements will be delivered directly to you on at least a quarterly basis from the 529 College Savings Plan sponsor. You are encouraged to review your account statements for accuracy. You may terminate the investment advisory agreement upon 30 days written notice. 401K Plan Advisory Services (Participant-Directed Plans) We offer Advisory Services to 401(k) plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include plan level investment advice regarding fund selection and investment options, development of an investment policy statement, performance reporting and advice on qualified default investment alternatives. These services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. We also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
• Diversification
• Asset allocation
• Risk tolerance
• Time horizon Our educational seminars may include other investment-related topics specific to the particular plan. We may also provide additional types of 401k Plan Advisory Services on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries shall be detailed in a written advisory agreement and be consistent with the parameters set forth in plan documents. Our fee for 401k Plan Advisory Services is based on the following tiered fee schedule: Value of Plan Assets Annualized Fee Under $1,000,000 0.50% $1,000,001 to $3,500,000 0.40% $3,500,001 to $5,500,000 0.30% Over $5,500,000 0.20% Our annual fee is billed and payable quarterly in arrears based on either the plan's asset value on the last day of the billing quarter or based upon the plan's average asset value during the billing quarter. If the advisory agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. The custodian of the Plan's assets will calculate our fee based on our fee schedule above, deduct the fee from the Plan's account and remit the fee to us. The Plan Sponsor may terminate the advisory agreement upon 30 days written notice and the Plan will incur a pro rata charge for services rendered prior to the termination of the agreement, which means the Plan will incur advisory fees only in proportion to the number of days in the quarter for which the Plan is under our management. As disclosed above, we offer various levels of advisory services to 401k Plans ("Plan") and to the participants of such plans (“Participants”). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act (“ERISA”). Pursuant to adopted regulations of the U.S. Department of Labor under ERISA Section 408(b)(2), we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan are described above, and in the advisory agreement that you have signed. Our compensation for these services is described above and in the advisory agreement. We may, with consent of the Plan, and in accordance with Plan documents, bill out- of-pocket expenses (such as overnight mailings, messenger, translation fees, etc.) at cost. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants. In providing services to the Plan and Participants, our status is that of an investment adviser registered under Investment Adviser Act of 1940, and we are not subject to any disqualifications under Section 411 of ERISA. In performing ERISA fiduciary services, we are acting as a non-discretionary fiduciary of the Plan as defined in ERISA Section 3(21). SIMPLE IRA Plus Plan Advisory Services (Participant-Directed Plans) The SIMPLE IRA Plus Plan is an employer-sponsored retirement savings program designed for smaller employers under 100 employees. This program combines many of the attributes of Individual Retirement Accounts (IRA’s) within a payroll-deduction retirement savings plan that may be offered by employers to assist their employees in saving for their financial future, but without many of the costs and regulatory obligations required of ERISA-qualified 401(k) programs and other plans. We provide Non-Fiduciary Advisory Services to SIMPLE IRA plans, their Plan Sponsors and their Participants. Currently, we only offer SIMPLE IRA services via the SIMPLE IRA Plus Plan program offered through the American Funds Mutual Fund Company. We will assist Plan Sponsors to establish and maintain a SIMPLE IRA Plus Plan through the American Funds Mutual Fund Company. Once a SIMPLE IRA Plus Plan has been established, we will offer enrollment meetings to introduce the plan to participants (employees) and assist participants (employees) with the set-up of their individual accounts. Plan participants (employees) will be establishing their accounts directly with the American Funds Mutual Fund Company, making their own investment selections from the available investment option offered in the program. Because the American Funds Mutual Fund Company SIMPLE IRA Plus Plan provides a predetermined list of investment options, our services will generally be non-discretionary in nature. The ultimate decision to utilize the program shall remain with the Plan Sponsor or other named fiduciary. At the request of the Plan Sponsor, we may, from time to time, also assist with new participant enrollment and provide investment-related educational seminars to plan participants on such topics as:
• Retirement Planning
• Asset allocation
• Risk tolerance
• Time horizon Educational seminars may include other investment-related topics that will be general in nature but may include information on investments specific to the program. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries, shall be detailed in a written advisory agreement and be consistent with the parameters set forth in plan documents. Fees for the SIMPLE IRA Plus Plan are based on the following tiered fee schedule based upon the aggregate value of the SIMPLE IRA Plus Plan accounts: Value of Assets Annualized Fee Under $1,000,000 0.50% $1,000,001 to $3,000,000 0.40% $3,000,001 to $5,000,000 0.30% Over $5,000,000 0.20% The adjusted quarterly fees are payable in arrears based upon the aggregate value of all participant accounts within the SIMPLE IRA Plus Plan on the last day of the billing quarter or based upon the plan's average daily balance as determined by the American Funds Mutual Fund Company’s recordkeeping system during the calendar quarter. American Funds Mutual Fund Company will calculate the aggregate fee for the previous calendar quarter. The resulting amount will be divided proportionately among participants in the plan on their account balances on the day the fees are processed. American Funds Mutual Fund Company will remit the quarterly fee to us in March, June, September, and December as applicable. The Plan Sponsor may terminate the advisory agreement upon 30 days written notice and the Plan will incur a pro rata charge for services rendered prior to the termination of the agreement, which means the Plan will incur advisory fees only in proportion to the number of days in the quarter for which the Plan is under our management. Seminars We may also provide seminars to retirement plan participants on topics which may include but may not be limited to education and enrollment. We will not render specific investment advice to anyone individual at such seminars and information provided will be of a general nature. The fee and fee-paying arrangements for seminars (if any) are negotiable and will vary on a case-by- case basis. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. We do not sponsor, manage or participate in a Wrap Fee Program. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Assets Under Management As of December 31, 2022, we managed $260,983,764 in client assets; $249,679,669 managed on a discretionary basis and $11,304,095 on a non-discretionary basis.