Scott Edward Upham

You will pay an asset-based fee, fixed fee, combination of both, or a wrap fee (hereinafter referred to as “Advisory Fees”) for our Investment Management and Financial Planning Services. As a result, if you pay an asset based fee, the more assets there are in your account, the more you will pay in fees, and the firm and your Advisor may therefore have an incentive to encourage you to increase the assets in your account. The annual fee for portfolio management services is billed either quarterly in advance based on the market value of the assets under management on the last day of the preceding calendar quarter, quarterly in arrears (after the services have been provided) based on the market value of the assets under management (as described in the investment advisory agreement) on the last day of the calendar quarter. Our clients will pay fees whether you make or lose money on your investment accounts. 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. The fees that you pay to our firm are separate and distinct from the fees and 2 expenses charged by mutual funds, exchange traded funds or the transaction charges and/or brokerage fees assigned by your respective account custodian. Our firm also offers, in limited circumstances, wrap fee program fees. The EPWA Wrap Fee Program will be offered to clients at EPWA’s discretion and in limited circumstances. This program is one under which specified fees that include securities transaction fees for certain mutual funds, custodial costs, administrative fees and trade-away fees (herein “Covered Costs”) are combined together with the client’s investment advisory fees. As such, these fees are consolidated into a single asset-based fee. Additionally, because of the consolidation of fees, the fee schedule assigned to wrap fee clients are usually higher than the typical asset-based advisory fee assigned to clients that are not EPWA Wrap Fee Program clients.

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 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. As a result of the way our Advisors are compensated, they are incentivized, therefore creating a conflict of interest, to move accounts that are not managed by our firm to our management or to encourage you to add assets to the accounts which we manage for you. For example, if you have assets in an account that is not managed by EPWA, your EPWA Advisor will be incentivized to recommend that the account be managed by EPWA. This may produce a recommendation to close, rollover, consolidate, or transfer the account. This recommendation creates a conflict of interest as it can increase the fee EPWA may earn, and analogously, the compensation of the respective advisor.

Our Advisors are compensated a percentage of the advisory fees we collect for the Investment Management and Financial Planning services we deliver. Our Advisors do not receive commission, trails, or any financial incentives for the securities we recommend. As a result of the way our Advisors are compensated, they are incentivized, therefore creating a conflict to move accounts to our management or add assets to the accounts which we manage for you.