David R. Penniall

We charge a fee based on the total assets in your account, subject to a minimum quarterly program fee of $1,250. This fee is generally payable quarterly in advance. The more assets in your account, the more you will pay in fees, and we may have an incentive to encourage you to increase the assets in your account.

Fees for our financial consulting services may be fixed, hourly, or based upon a percentage of assets under supervision. The specific fee amount and the fee-paying arrangements are determined on a case-by-case basis and will be outlined in your agreement.

Our fee does not include management fees charged by Independent Managers or any applicable charges imposed by custodians, brokers or other third parties such as, platform fees, brokerage commissions, transaction fees, custodial fees, wire transfer/electronic fund fees, or other fees/taxes in connection with securities transactions in your account. The Independent Manager fees may be greater than our fees. Money market funds, mutual funds, and ETFs also charge their own internal management fees.

Additional Information: You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. Please also see Item 5 of Form ADV, Part 2A.

When we act as your investment adviser, 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. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means.

• We offer our own real estate, sustainable, and credit-oriented investment funds (“Funds”) to clients. While clients do not pay additional fees for investing in the Funds, we have an incentive to grow the assets in the Funds.

• We may also recommend that clients invest in mutual funds managed by a related adviser, or an interval fund managed by us (“Related Funds”). We have an incentive to recommend the Related Funds because we or our related adviser receive fees based on their total assets.

• Some of our employees are licensed insurance agents of a related insurance agency and receive commissions for recommending insurance products, which creates a financial incentive. Clients will not pay both a management fee and commission for such products.

• We participate in referral programs in which we pay custodians a portion of our fee collected from clients they refer to us. We have an incentive to recommend that clients maintain their accounts with such custodians in order to continue receiving their products/services and participating in their referral programs.

Additional Information: Please also see Items 10-12, 14 of Form ADV, Part 2A.

Our financial professionals earn salaries and, when applicable, merit bonuses for performing advisory functions. Some of our financial professionals may receive compensation that is based, at least in part, on the number or amount of client referrals or new accounts brought to the firm. Some of our financial professionals earn additional compensation from insurance or brokerage commissions. For more information regarding these activities, refer to Item 10 of Form ADV, Part 2A and your financial professional’s Form ADV, Part 2B Supplement.