A. Services WRAP PROGRAM. Through a Wrap Fee Program (the “Program”) North Star provides personalized discretionary investment management services to customers of NewEdge Securities, Inc. (a “Program Broker”) for equity and balanced and fixed income portfolios. Clients are asked to provide North Star with certain information with respect to their current financial holdings, investment objectives, risk tolerance, liquidity needs, and time horizon. The Firm will also inquire as to the restrictions the client wishes to impose on the management of the accounts. From the information that is supplied by the client, North Star constructs an investment policy that it believes is suitable for that client. The Program Broker places and/or executes the transactions in the advisory accounts. The Program client gives North Star complete discretionary authority to invest funds without prior consent to each transaction. Accordingly, North Star has the authority to determine the securities to be purchased or sold and the amount of securities to be purchased or sold within the Program account. B. Cash Sweep Accounts Account custodians generally require that cash proceeds from account transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account is generally lower than those available in money market accounts. North Star may purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds or deposits, unless North Star reasonably anticipates that the cash proceeds will be utilized during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the amount of dispersion between the sweep account and a money market fund, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. North Star does not receive compensation from these programs. Please contact North Star to address any questions you may have regarding the options available for cash balances. C. Fees The client pays a “wrap fee” for the advisory services offered by North Star and the execution of transactions in the advisory account by the Program Broker. For such accounts, North Star directs all account brokerage transactions to the Program Broker to prevent incurring additional transaction charges outside of the wrap fee. Generally, the wrap fee for such accounts is charged in accordance with the following fee schedule: AUM Balanced and Equity Fixed Income Up to $500,000 2.00% 1.50% Over $500,000 1.50% 1.25% "AUM" means the assets under the management of North Star for a particular client or client account. The fees listed in the schedules above are annualized figures. Fees will be charged quarterly and in arrears. The quarterly fee is based upon the market value of all assets held within the client's account on the last business day of the calendar quarter. Additional deposits to the account are subject to the same fee procedures. The client may be charged a pro rata fee in the event the client's service is terminated on a day other than the last business day of the month. In that event, the pro rata fee will be due and payable upon termination of the service. North Star may adjust the fee schedule upon thirty (30) days' prior written notice to the client. In certain instances, fees may be negotiable. A negotiated fee schedule must be pre-approved by a member of the Firm’s Senior Management. The client's account will be debited for the above-mentioned fees. Fees are collected by the Program Broker from the amount of any contribution or transfer, from available cash in the client's account, or by liquidating the client's assets held in the client's account in an amount equal to the fees that are due. The Program Broker remits all or a portion of the wrap fee to North Star. Typically, NewEdge Securities, Inc. will remit 0.50% (annualized) of the wrap fee to North Star and keeps the remainder of the wrap fee for execution services. WRAP ACCOUNTS SPONSORED BY OTHER FINANCIAL INSTITUTIONS. North Star is a portfolio manager for certain wrap fee programs sponsored by financial institutions or broker/dealer firms that may make available such programs to their customers. Generally, annualized fees charged to such financial institutions for the managed accounts are 0.50% of the AUM. FEE CONSIDERATIONS. In determining whether to establish a Program account, the client should be aware that the overall cost to the client of the Program may be higher or lower than the client might

incur by purchasing separately the types of securities available in the Program. The Program costs may be more particularly when there are a low number of transactions. The Program may not be suitable for clients whose accounts have fewer than a certain number of transactions per year or for clients who simply want to purchase individual securities. To meaningfully compare the cost of the Program with unbundled services, the client should consider the portfolio turnover rate as discussed with North Star, North Star’s standard advisory fees for non-wrap accounts, which are set forth on North Star’s Brochure, and brokerage commissions that would be charged by the Program Broker or by other broker/dealers. Additionally, North Star might not be able to obtain the most favorable price if it is unable to aggregate or batch the trades from these accounts with other client trades. Clients should also understand that custody of a client’s assets by the Program Broker may limit or eliminate North Star’s ability to obtain best price and execution of transactions in over-the-counter securities purchased or sold in the Program account. LOWER FEE DISCLOSURE. North Star's wrap fees may be higher than charged by other investment advisers offering comparable services. D. Other Fees In addition to the wrap fee, other fees may apply. The wrap fee does not include: (1) sales loads, sales charges, management fees, administrative fees, account maintenance fees, and other fees that may be charged by the custodian (if any), and/or by the distributor, issuer or fund issuing the securities purchased and sold within the Program accounts; (2) administrative fees, such as wire fees, charged by the Program Broker or any clearing firm utilized by the Program Broker for the clearance and settlement of the trades executed in the advisory accounts; (3) certain odd-lot differentials; (4) transfer taxes; (5) postage and handling fees; or (6) advisory fees and expenses of mutual funds (including money market funds), closed-end investment companies, exchange-traded funds (“ETFs”), or other managed investments, if any, that are held in the Program account. The client is solely responsible for paying all such charges. When the Program Broker acts as the client's agent in purchasing securities in the over-the-counter market, the client should be aware that the wrap fee does not cover certain costs associated with such securities transactions. For these transactions, the Program Broker must approach a dealer or market maker to purchase or sell the security and the client will be responsible for paying the fees, commissions, or other charges for these transactions. In addition, the client should understand that mutual funds and certain ETFs pay management fees to their investment advisers, which reduce their respective assets. To the extent that the client’s portfolio has investments in mutual funds or ETFs, the client may pay two levels of advisory fees for the management of their assets: one directly to North Star, and the other indirectly to the managers of the mutual funds and ETFs held in the Program portfolios. Clients should understand that mutual funds or closed-end investment companies purchased for a Program account may pay the Program Broker a proportionate share of certain additional fees or expenses collected from the client (e.g. 12b-1 or shareholder servicing fees). Such fees will be retained by the Program Broker. E. Compensation The investment adviser representative who recommends the Program to the client receives compensation as a result of the client's participation in the Program. The amount of this compensation may be more than what the investment adviser representative would receive if the client paid separately for investment advice, brokerage, and other services. The investment adviser representative, therefore, may have a financial incentive to recommend the Program over unbundled services. North Star serves as the investment adviser to the North Star Mutual Funds (defined in Item 6.B below). In consideration of the investment advisory services provided by North Star to the North Star Mutual Funds, generally, North Star is entitled to receive from the North Star Mutual Funds an investment advisory fee up to 1.00% per annum of each fund’s average net assets computed daily and paid monthly. Managed Fees do not include separate professional fees provided by North Star or its affiliates. These are two separate fees at North Star and the client may receive an invoice for management services and a separate invoice for professional services (e.g., financial planning and/or accounting services). F. Termination The Program may be terminated either by North Star or by the client upon thirty (30) days' written notice to the other party.