Gregory David James

• We charge the greater of a minimum fee or a percentage of assets under management for our wealth management, portfolio management and retirement plan services. These fees are assessed quarterly, in advance. The more assets your account has, the more you will pay in fees. This gives us an incentive to encourage you to increase the assets in your account.

• We also charge fixed fees for our monitoring, consulting and coaching services which we invoice quarterly in advance. When you pay us only an hourly or fixed fee, it will be assessed in two installments and it will not include fees for implementing recommendations. This creates an incentive to recommend additional advisory services to you for which additional fees would be charged.

• In addition to our fees, you will incur additional fees and costs related to the investments in your account, such as custodian fees, account maintenance fees, transaction costs, surrender charges, wire transfer and electronic fund fees, internal management fees of mutual funds and variable annuities, and other product related fees such as redemption fees.

• 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.

More detailed information regarding fees can be found in our Form ADV, Part 2A Brochure.

• 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 receive client referrals from third parties and employees to whom we pay referral fees. This is a conflict of interest because we have an incentive to pay referral fees so that the third parties or employees will refer clients to us that they otherwise might not refer to us.

• We only make money from the fees we are charging clients.

• We are fiduciaries to you. That means we are required to act in your best interest throughout our entire advisory relationship.

More detailed information regarding our conflicts of interest can be found in our Form ADV, Part 2A Brochure.

Our financial professionals are paid a salary and may also be paid a bonus. Any bonus is based not only on the firm’s overall profitability and attainment of pre-set metrics but also when they obtain new clients for us. This is a conflict of interest because it creates an incentive for our financial professionals to recommend our investment advisory services to you.