A. JCN FINANCIAL & TAX ADVISORY WRAP PROGRAM The Registrant is the sponsor of the JCN Financial & Tax Advisory Wrap Program (hereinafter the “Program”). Under the Program, the Registrant is able to offer discretionary investment management services, for a single specified annual Program fee, inclusive of trade execution, custody, reporting, and investment management fees. However, clients may pay fees for, but not limited to, trustee fees, mutual fund expenses, ETF expenses and mark-ups, mark-downs, or spreads paid to market makers from whom securities were obtained by the broker. Such fees are in addition to any fees paid to the Registrant and are between the client and the account custodian. The current annual Program fee ranges from negotiable to 2.20% of assets under management, as follows: Assets Under Management Annualized Fee First $1,000,000 2.20% Next $500,000 (up to $1,500,000) 2.10% Next $500,000 (up to $2,000,000) 2.00% Over $2,000,001 1.90% LPL Financial LLC, member FINRA/SIPC, (“LPL Financial”) shall serve as the custodian for Program accounts. Fee Calculation: The fee charged is calculated as described above and is not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of an advisory client, pursuant to Section 205(a)(1) of the Investment Advisers Act of 1940, as amended (hereinafter the “Act”). The Registrant’s investment advisory fee is negotiable at its 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. As a result of these factors, similarly situated clients could pay different fees, the services to be provided by the Registrant to any particular client could be available from other advisers at lower fees, and certain clients may have fees different than those specifically set forth above Fee Payment: Clients will be charged in advance at the beginning of each calendar quarter based upon the value (market value or fair market value in the absence of market value, plus any credit balance or minus any debit balance, including adjustments for inflows and outflows), of the client's account at the end of the previous quarter. During the initial quarter of service the client will be charged a pro-rated fee based upon the number of days remaining in that calendar quarter and the market value of the assets under management after the transition. Termination of Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of prior written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. Client Responsibilities: In performing any of its services, the Registrant shall not be required to verify any information received from the client or from the

client’s other professionals, and is expressly authorized to rely thereon. Furthermore, unless the client indicates to the contrary in the client’s Investment Policy Statement, the Registrant shall assume that there are no restrictions on its services, other than to manage the account in accordance with the client’s designated investment objective. Moreover, it remains each client’s responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Registrant’s previous recommendations and/or services. Investment Performance: As a condition to participating in the Program, the participant must accept that past performance may not be indicative of future results, and understand that the future performance of any specific investment or investment strategy (including the investments and/or investment strategies purchased and/or undertaken by the Registrant) may not: (1) achieve their intended objective; (2) be profitable; or, (3) equal historical performance level(s) or any other performance level(s). 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 percentage wrap-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 wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately and/or if the Registrant were to negotiate transaction fees and seek best price and execution of transactions for the client's account. C. The Program’s wrap fee does not include certain charges and administrative fees, including, but not limited to, transaction charges (including mark-ups and mark-downs) resulting from trades effected through or with a broker-dealer other than LPL Financial, 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. Such fees and expenses are in addition to the Program’s wrap fee. Asset Based Pricing Limitations: We recommend that our clients enter into an asset based pricing agreement with the account custodian, generally LPL Financial. Under an asset based pricing arrangement, the amount paid to the custodian for account commission/transaction fees is based upon a percentage (%) of the market value of the account (generally, the greater the market value, the lower the %). This differs from transaction-based pricing, which assesses a separate commission/transaction fee for each account transaction. Account investment decisions are driven by security selection and anticipated market conditions and not the amount of transaction fees payable by to the account custodian. D. Registrant’s representatives shall not receive any additional compensation for recommending a wrap fee program to a client.