The Investment Advisor Charges an Asset Based Management Fee Based on the Total Value of Your Portfolio or Retirement Plan. The Investment Advisor Also Charges Flat Fees for Financial Planning for Clients Who Want Financial Planning Only, Hourly Fees for Consulting Services and Flat Fees for Feasibility Studies Regarding the Creation and Maintenance of and Investments Held Within Retirement Plans Subject to Certain Minimum Fees. Please See Form ADV Part II the Disclosure Document of The Investment Advisor for a More Detailed Description of the Fees The Investment Advisor Charges.

This is important because:

• The Investment Advisor Does Not Charge Commissions or Transaction Fees for the Purchase or Sale of Financial Products or Services. The Investment Advisor Provides Investment Advice for Portfolio and Wealth Management and Offers Services Surrounding the Provision of Investment Advice such as Financial Planning. The Investment Advisor also Provides Investment Advice and Services regarding the Creation and Maintenance of Retirement Plans and the Investments Held Within Retirement Plans.
• As Part of the Advisory Service The Investment Advisor Provides to You The Investment Advisor Will Place Trades on Your Behalf Based on Your Agreement and Subsequent Authorization to Implement the Recommendations The Investment Advisor Presents to You. You May Incur Transaction Fees for the Placement of these Trades by Your Custodian as well as Fees and Expenses for Mutual Funds and other Financial Products and Services.
• However, The Investment Advisor is Not Compensated by Transaction Fees, Commissions, or Other Fees or Expenses for the Purchase or Sale of Financial Products or Services Charged by Your Custodian or Any Other Entity or Financial Institution Which May be Involved in the Provision of Financial Products or Services to You. The Investment Advisor is Only Compensated by the Fees You Pay The Investment Advisor Directly. Therefore, The Investment Advisor’s Only Interest is in Meeting Your Goals and Objectives for Your Portfolio.

Therefore:

• The Investment Advisor Earns its Fees Only for Providing Investment Advice, Financial Planning, Advice Regarding Retirement Plans and Consulting Fees.
• The Fees of The Investment Advisor are Paid Only by You. Therefore, The Investment Advisor’s Responsibilities and Loyalties are Only to You.
• The Investment Advice and Recommendations The Investment Advisor Provides to You is Unbiased and is Based on Your Goals and Objectives.

As a Primary Objective The Investment Advisor Seeks to Protect the Value of Your Principal. At the Same Time The Investment Advisor Incorporates Your Goals and Reasons for Investing Into Investment Recommendations Based on Your Investment Objectives and Needs. Your Portfolio is Designed to Help You Meet Your Goals in Combination with the Objective of Protecting Your Principal.

Investing in Securities Always has the Risk of Loss. The Investment Advisor Attempts to Help You Manage this Risk.
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The Purpose of The Investment Advisor as a Registered Investment Advisory Firm is to Provide Impartial, Objective Investment Advice to You as a Client. This is a Much Different Business Model than Firms Who Earn Revenues from Transaction Fees. When a Financial Advisor Earns Their Compensation in the Form of a Transaction Fee That Financial Advisor Has a Vested Interest That You Buy or Sell a Security. This Can Create a Conflict of Interest Between the Financial Advisor and Their Client Because the Financial Advisor’s Primary Interest is to Generate a Transaction Fee or Commission to Get Paid. The Investment Advisor Takes Transaction Fees and Commissions Out of the Equation and Replaces Them With an Asset Based Compensation Structure that Rewards The Investment Advisor for Monitoring Your Portfolio and Making Recommendations in Your Best Interest.

Some Examples of the Types of Firms that Offer Investments Range from Brokerage Firms, Insurance Companies, Banks and Mutual Fund Companies. Some are Completely Transaction Fee and Commission Based While Others Employ a Hybrid Model including Transaction Fees, Commissions and Asset Based Fees.

One Should Always Look at Both a Firm’s Primary Line of Business and How that Firm Compensates its Advisors. How a Firm’s Primary Line of Business Impacts Investment Recommendations and the Services Provided to its Client’s Portfolios Should be Viewed in Combination With That Firm’s Compensation Practices. For Example, is an Insurance Company That Sells Mutual Funds or Offers Brokerage Services Truly in the Business of Helping You Manage Your Portfolio? Is Their Advice Objective?

Is a Bank Who Sells Mutual Funds and Annuities in the Business of Managing Your Portfolio or is the Bank Trying to Attract More Deposits and Create Revenue by Selling Mutual Funds and Annuities? Does the Bank Offer a True Investment Advisory Service?

With Respect to Other Registered Investment Advisors. Is the Advisory Firm Really in the Business of Providing Third Party, Objective Investment Advice or Does the Firm Profit From Transaction Fees for the Purchase and Sale of Securities and From the Sale of Insurance and Other Products for a Commission.

As a Registered Investment Advisory Firm The Investment Advisor Must Meet a High Standard in the Management of Your Portfolio. The Investment Advisor is Deemed to be a Fiduciary. Being a Fiduciary Means a High Degree of Responsibility to You Our Client with Respect to Disclosure and Acting in Your Best Interest. Therefore, The Investment Advisor Does Not Sell Financial Products for a Commission or Profit from Transaction Fees for the Purchase or Sale of a Security.

The Investment Advisor is in the Business of Helping You Manage and Monitor Your Portfolio. The Investment Advisor is not in the Business of Selling Investments. Which is Why The Investment Advisor is Not Compensated for the Purchase or Sale of Securities as a Result of the Recommendations The Investment Advisor Makes to You. This Helps Insure Recommendations are Made in Your Best Interest and Helps Eliminate this Conflict of Interest. The Investment Advisor Offers Financial Planning to Help You Define Your Goals and Objectives. The Investment Advisor is Also in the Business of Helping You Protect Your Investment Assets by Working with Your Attorney, Accountant and other Advisors to Help You Manage Your Investments for Your Benefit. For More Information Review the Portfolio Management, Financial Planning, Investment Philosophy and Wealth Management Pages of This Web Site.
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Yes, Financial Planning is Included as Part of the Investment Advisory Service The Investment Advisor Offers You as a Client. If You are an Investment Advisory Client There is No Charge for Financial Planning.

If You are a Prospective Investment Advisory Client or a Client Who Wants Financial Planning Only Financial Planning is Charged For. These Fees are Fully Outlined in Form ADV Part II the Disclosure Document of The Investment Advisor.

To Learn More About the Financial Planning Services of The Investment Advisor Please Review the Financial Planning Page of This Web site.
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Shareholder Service Group is a Broker-Dealer That Acts as Both a Financial Intermediary and Third Party Vendor of The Investment Advisor. As a Broker-Dealer and Financial Intermediary Shareholders Service Group is a Conduit for the Execution of Trades for Clients of The Investment Advisor. Shareholders Service Group Handles the Execution of Trades for Investments Such as: Stocks, Bonds, Mutual Funds, Index and Exchange Traded Funds, Money Markets, CD’s and Other Publicly Traded Investments.

Pershing is a Division of Bank of New York Mellon. Pershing is a Custodian of Financial Assets. Pershing also Clears Trades Executed through Shareholders Service Group.

Pershing Holds Assets in Client Accounts for Which Shareholders Service Group Executes Trades. Please Visit www.pershing.com/strength_stability.html to See the Value of Assets Pershing and Bank of New York Mellon Hold in Custody.

More Information About Shareholders Service Group is Available at: www.ssginstitutional.com

Shareholders Service Group is a Broker-Dealer Exclusively Serving Registered Investment Advisory Firms. Shareholders Service Group Offers The Investment Advisor and its Clients Access to a Broad Range of Investments at a Very Reasonable Cost. Senior Management of Shareholders Service Group Developed Their Firm Around a Pricing Structure Comparable to Most Discount Brokerage Firms. As a Result The Investment Advisor is Able to Provide You, its Client Low Cost Access to the Products and Services The Investment Advisor Recommends.

Bank of New York Mellon is One of the Strongest Custodial Banks in the United States. Pershing an Investment Custodian is Also One of the Strongest Investment Custodians in the United States. When Evaluating Custodians for its Clients The Investment Advisor Believes the Financial Strength of Pershing Combined With the Financial Strength of its Parent Bank of New York Mellon, the Account Insurance Provided to Account Holders, the Fact Pershing and Bank of New York Mellon’s Status as Custodial Institutions Tends to Make them Less of a Risk Than Pure Investment Banks Makes Pershing One of the Best Choices as an Institution to Hold Your Accounts, Savings and Investments.

Since The Investment Advisor Does Not Have Custody of Your Portfolio The Investment Advisor Does Not Offer Account Insurance. Account Insurance is provided through the Custodian Who Holds Your Accounts and Investment Assets. Through The Investment Advisor’s Business Relationship With Shareholders Service Group and Pershing, Pershing is the Custodian of Your Portfolio. Therefore, Account Insurance is Provided by Pershing in Association with Shareholders Service Group.

There are Several layers of Account Insurance Which Can be Provided Through a Custodian. The First Line of Defense in the Event of a Default by the Firm That Holds Your Accounts and Investments is Provided by SIPC (Securities Investor Protection Corp).

At Shareholders Service Group and Pershing Your Assets are Protected by SIPC(Securities Investor Protection Corporation). SIPC Coverage Does Not Protect Against Loss Due to Market Fluctuation.

If You Choose Another Custodian Through Which Your Assets are to be Held Then the Custodian You Choose Will Have Their Own Account Insurance Arrangements in the Event of a Default. In General SIPC Covers Assets Held at a Custodian. More Information About SIPC is available at www.sipc.org

Pershing also Offers Private Account Insurance Over and Above the Limits Provided by SIPC. Account Insurance in Excess of the Limits covered by SIPC can vary from Custodian to Custodian. Accounts Custodied at Pershing through Shareholders Service Group are Covered by Additional Private Insurance.

Pershing’s limits Regarding Account Insurance Can be Viewed at:
http://www.pershing.com/strength_stability.html

Additionally, FDIC (Federal Deposit Insurance Corporation) Protects Insured Deposits and Brokered CD’s. More Information is Available About FDIC at: www.fdic.gov

A Brochure is Also Available Describing Shareholders Service Group’s Account Insurance Arrangements which Can be Provided Upon Request. More Information about Shareholders Service Group Can be Viewed at:www.ssginstitutional.com

The Investment Advisor Does Not State You Will Achieve Any Specific Gain or Loss for Your Portfolio. The Recommendations and Services The Investment Advisor Provides to You Are Designed to Provide You With the Best Publicly Available Information From Which to Make Decisions About Your Portfolio. The Investment Advisor Will Research Your Investments Held in Your Portfolio, Organize this Information, Analyze it, Put it Into Context, Make Recommendations and Help You Make Decisions About Your Investments With it.

The Recommendations The Investment Advisor Makes to You Will Also be Tailored to Your Goals, Objectives and Circumstances Which are Unique to You as an Investor. These Can include Your Needs for Growth, Income, Your Circumstance such as Your Tax Bracket, Age, Family Needs and the Myriad of Purposes for Which You are Investing.

Your Needs as a Client are Unique. Your Portfolio is Managed to Your Unique Needs. The Services The Investment Advisor Provides to You are Highly Customized Services. This is True for Each and Every Client. Therefore, Performance May be Entirely Different for Each and Every Client Based on Their Needs. You Hire The Investment Advisor to Help You Manage and Monitor Your Portfolio Based on Your Unique Needs and Circumstances.

Yes. The Investment Advisor has Arranged for You to Receive Performance Information for Your Accounts Should You Decide to Hold Your Accounts With Shareholders Service Group and Pershing, a Division of Bank of New York Mellon.

If You Choose to Hold Your Accounts With Your Current Custodian or Choose Another Custodian the Policies of Your Custodian Regarding Performance Reporting Will Apply.

Yes. At the Time You move Your Accounts to Shareholders Service Group and Pershing You Will be Asked to Supply the Cost Basis of the Securities Held in Your Accounts. This Information Will be Recorded and Archived. When New Securities are Purchased the Cost Basis at the Time of Purchase Will be Captured and Archived.

If You Choose to Hold Your Accounts at Your Current Firm or Choose Another Custodian the Policies of Those Firms Regarding the Collection and Archival of Cost Basis Information Will Apply.

The Investment Advisor is Not Compensated for the Sale of Load Funds. The Investment Advisor is Only Compensated by the Fees You Pay Directly to The Investment Advisor.

Therefore, The Investment Advisor Strives to Reduce Your Investment Expenses Wherever Possible. As Such, The Investment Advisor Has a Preference for Using No Load Funds in Your Investment Portfolio. However, Cost is Not the Only Factor in Investment Selection. Therefore, Where Appropriate, Where the Need Calls for it and is Justified by the Performance of the Fund The Investment Advisor May Recommend a Load Fund.

Either You or The Investment Advisor May Terminate the Advisory Relationship by Telephone and Confirmed in Writing Within 3 Business Days. There Shall Be No Penalty for Termination. At Such Time Any Fee Owed to The Investment Advisor Shall be Paid by You as of the Effective Date of Termination. Upon The Investment Advisor’s Receipt of Written Notice of Termination from You, The Investment Advisor Will Immediately Discontinue All Trading and Investment Management Activities. The Investment Advisor Will Close All Open Trade Orders. You May Issue Final Trade Instructions Orally at the Time of Termination and in Writing in Your Termination Letter. You Will Hold Sole Responsibility for the Assets Held in Your Account(s) at the Custodian and for Removing The Investment Advisor’s Authorization to Access Account Information and Place Trades in These Accounts.

This Policy is More Fully Outlined in The Investment Advisor’s Disclosure Document Form ADV Part II. Form ADV Part II is Available to You Upon Your Request, or Prior to or At the Time You Become a Client of The Investment Advisor.