Richard D. Cundey

• Investment Advisory and Aggregated Reporting Service Fees. Our fees for investment advisory and aggregated reporting services vary by client based upon the services provided and other considerations deemed relevant, but are generally payable quarterly in advance, calculated as a percentage of the amount of assets under management (“AUM”) or assets under advisement (“AUA”) you have with us. We generally apply a tiered schedule where fee rates decrease as AUM or AUA increase. Legacy clients may be grandfathered to a flat fee schedule, rather than a tiered fee schedule, at an annual rate not to exceed 1.5% per annum (unless otherwise agreed to with the client). Advisory and aggregated reporting fees are generally computed based on the value of your AUM or AUA on the last day of the calendar quarter. We generally charge an annual minimum fee of $8,000 and request clients to have investable assets of at least $1,000,000. These minimum requirements may have the effect of making our services impractical for certain individuals or entities with fewer investable assets given the effective annual rate of fees that would be charged. Because we generally charge fees on all your assets that we manage or report on, the more assets in your account, the more you will pay in fees, and therefore we have an incentive to encourage you to increase your assets in your account(s). If a portion of your assets are invested in a SMA (as described above), then in addition to our fee you will be charged a separate and additional fee by the SMA Manager. Given that you may make additions to and/or withdrawals from your account at any time, we may (upon written notice to you or as otherwise agreed upon with you) adjust our advisory or aggregated reporting fees to account for material deposits or withdrawals from your account during a billing period.

• Financial Planning and Consulting Service Fees. Financial planning fees are determined based on the nature of the services provided and the complexity of your individual circumstances. Fees are calculated and charged on a fixed fee basis or an hourly basis. We may reduce or waive the fixed or hourly fee if you choose to engage us for other services.

• Other Fees. You may incur additional fees and expenses on your investments such as: custodian fees; account maintenance fees; fees related to mutual funds, exchange traded funds, and variable annuities; and other transactional fees and product level fees.

• Third Party Fees. All fees for our services are separate and distinct from the fees and expenses that may be charged by SMA Managers and independent advisors related to the assets held in investment advisory services accounts, including without limitation, fees that investment vehicles charge to their shareholders. The additional fees applicable to these holdings generally include a management fee, performance-based compensation (if applicable), other expenses, and a possible distribution fee. If the investment vehicle also imposes sales charges, a client may pay an initial or deferred sales charge. Such fees and expenses may be material and may negatively impact the value of the assets held in investment advisory services accounts or the performance thereof.

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.

For additional information, please see Items 5.E in our ADV Part 1 and Item 5 of 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.

Certain custodians offer services to us intended to help manage and further develop our business. These services are provided to us at no cost and include educational conferences and events, consulting on technology, compliance, legal, and business needs, publications and conferences on practice management and business succession, access to employee benefits providers, consulting services, and insurance providers. A custodian may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. The availability of these services from the custodian benefits us because we do not have to pay for the custodians’ services as long as our clients collectively keep a specified amount of their assets in accounts at the custodian. This creates a potential conflict of interest, as we recommend clients to open accounts with selected custodians.

For additional information regarding our conflicts of interest, please see our Form ADV Part 2 Brochure

Our financial professionals receive a base salary and bonus based on both individual and firm performance factors including revenue generated from client assets they service. The receipt of the compensation linked to revenue generated from client assets creates a conflict of interest as it incentivizes our professionals to increase fees and encourage you to increase the assets in your account.