A. INVESTMENT ADVISORY SERVICES The client can determine to engage the Registrant to provide discretionary investment advisory services on a wrap fee basis. (See discussion below). If a client determines to engage the Registrant on a wrap fee basis, the client will pay a single fee for investment advisory services, brokerage and custody, inclusive of commission and transactions costs. The services included in a wrap fee agreement will depend upon each client’s particular need. Certain of the Registrant’s legacy clients still may have agreements in place with the Registrant for advisory services on a non-discretionary wrap-fee basis. SYNTAL CAPITAL PARTNERS WRAP PROGRAM The Registrant is the sponsor and investment manager of the Syntal Capital Partners Wrap Program (the “Program”). Under the Program, the Registrant and/or independent investment managers are able to offer participants discretionary and/or non-discretionary investment management services, for a single specified annual Fee, inclusive of trade execution, custody, reporting, and investment management fees (“Program Fee”). The Registrant charges an annual Program fee for participation in the Program. The Program Fee is charged as a percentage of assets under management, on a non-graduated basis, as follows: Market Value of Portfolio Annual Fee % Accounts valued $5,000,000 and below Up to 2.00% Accounts valued between $5,000,000 and $10,000,000 Up to 1.65% Accounts valued between $10,000,000 and $24,999,999 Up to 1.40% Accounts valued at $25,000,000 Up to 1.25% Accounts valued in excess of $25,000,000 Negotiable The Registrant’s investment advisory fee is negotiable at Registrant’s discretion, depending upon objective and subjective factors including but not limited to: the amount of assets to be managed; portfolio composition; the scope and complexity of the engagement; the anticipated number of meetings and servicing needs; related accounts; future earning capacity; anticipated future additional assets; the professional(s) rendering the service(s); prior relationships with the Registrant and/or its representatives, and negotiations with the client. Similarly situated clients could pay different fees based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). In addition, similar advisory services may be available from other investment advisers for similar or lower fees. A limited number of Registrant’s ultra-high net worth clients require Registrant to provide ongoing business consulting services. For those clients, their investment advisory agreement shall reflect a deviation from our standard percentage of “assets under management” fee structure referenced above. As described in the client’s investment advisory agreement, the client shall pay Registrant the greater of the Program Fee (based upon a percentage of assets under management) or a separately negotiated annual minimum fee. No client is required to enter into this alternative fee arrangement, and once commenced, any client is free to terminate the arrangement, upon written notice to Registrant. If a client is subject to the negotiated minimum annual fee, such client’s fee will exceed the asset-based fee referenced above. Under the Program, the Registrant may be provided with written authority to determine which securities and the amounts of securities that are bought or sold. Any limitations on this discretionary authority shall be included in the written agreement between each client and the Registrant. Clients may amend these limitations, in writing, at any time. The client shall have reasonable access to one of the Registrant’s investment professionals to discuss their account. Clients are required to open brokerage accounts and enter into new account agreements with Fidelity Institutional Wealth Services (“Fidelity”) and Pershing Advisors Solutions, LLC through Pershing LLC (“Pershing”), or other broker-dealers approved by Registrant under the Program. Except as discussed above, the Registrant does not require any minimum annual fee for investment advisory services.

The Wrap Fee Agreement between the Registrant and the client will continue in effect until terminated by either party by written notice in accordance with the terms of the Wrap Fee Agreement. Upon termination, the Registrant shall refund the pro-rated portion of the advanced advisory fee paid based upon the number of days remaining in the billing quarter. Fee Calculation: The fee charged is calculated as described above and is not charged on the basis of a share of capital gains or capital appreciation of the funds or any portion of the funds of an advisory client. Fee Payment: Registrant’s annual investment advisory fee shall be prorated and paid monthly, in arrears, based upon the market value of the account on the last business day of the previous month. Investment Risk: Investing in securities involves risk of loss that clients should be prepared to bear. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Registrant) will be profitable or equal any specific performance level(s). Investors generally face the following investment risks: B. Participation in the Program may cost more or less than purchasing such services separately. Also, the Program Fee charged by Registrant for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. Depending upon the Program Fee charged by the Registrant, the amount of portfolio activity in the client's account, and the value of custodial and other services provided, the Program Fee may or may not exceed the aggregate cost of such services if they were to be provided separately by Registrant or another firm who may provide such services on a non-wrap fee basis. Wrap Program-Conflict of Interest. Registrant provides services on a wrap fee basis as a wrap program sponsor. Under Registrant’s wrap program, the client generally receives investment advisory services, the execution of securities brokerage transactions, custody and reporting services for a single specified fee. Participation in a wrap program may cost the client more or less than purchasing such services separately. The terms and conditions of a wrap program engagement are more fully discussed in Registrant’s Wrap Fee Program Brochure. Because wrap program transaction fees and/or commissions are being paid by Registrant to the account custodian/broker-dealer, Registrant could have an economic incentive to maximize its compensation by seeking to minimize the number of trades in the client's account. C. The Program Fee does not include certain charges and administrative fees, including, but not limited to, fees charged by independent managers, asset management platform fees, transaction charges (including mark-ups and mark-downs) resulting from trades effected through or with a broker-dealer other than Fidelity and/or Pershing, transfer taxes, odd lot differentials, exchange fees, interest charges, American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with regard to client accounts. Client accounts may invest in mutual funds (including money market funds) and ETFs that have various internal fees and expenses (i.e., management fees), which are paid by these funds but ultimately borne by clients as a fund shareholder. All of these fees and expenses are in addition to the Program Fee. D. Registrant’s related persons who recommend the Program to clients may receive compensation as a result of a client’s participation in the Program. However, we do not offer non-wrap programs, so a related person would not face a conflict in recommending the wrap fee program over a non-wrap fee program. Notwithstanding, clients are reminded that there may be other wrap fee programs or non-wrap fee programs which may be more suitable. The client retains absolute discretion over all implementation decisions and is free to accept or reject any recommendation from the Registrant’s related persons.