Robert J. Mooney

• Transaction-based fees. You will pay us a fee every time you buy or sell an investment. This fee, commonly referred to as a commission, is based on the specific transaction and not the value of your account.

• With stocks or exchange-traded funds, this fee is usually a separate commission. With other investments, such as bonds, this fee might be part of the price you pay for the investment (called a “mark-up” or “mark down”). With mutual funds, this fee (typically called a “load”) reduces the value of your investment.

• Some investments (such as mutual funds and variable annuities) impose additional fees that will reduce the value of your investment over time. Also, with certain investments such as variable annuities, you may have to pay fees such as “surrender charges” to sell the investment.

• Our fees vary and some are negotiable. The amount you pay will depend, for example, on how much you buy or sell, what type of investment you buy or sell, and what kind of account you have with us.

• We may charge you additional fees, such as custodian fees, account maintenance fees, asset movement fees, mutual fund transfer fees, and account inactivity fees.

• As you undertake more transactions in your account, you will incur more fees. We benefit from the fees you pay and therefore have a conflict of interest as regards recommending transactions to you.

• From a cost perspective, you may prefer a transaction based fee if you do not trade often or if you plan to buy and hold investments for longer periods of time.

• Please see our Ancillary Fee Schedule here: https://snowdenlane.com/adv/

• 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.

• When we provide you with a recommendation as your broker-dealer, we must act in your best interest and not place our interests 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 recommendations that we provide you.

• When we provide any service to you, we must treat you fairly and comply with specific obligations. Unless we agree otherwise, we are not required to monitor your portfolio or investments on an ongoing basis.

• Our interests can conflict with your interests. When we provide recommendations, we must eliminate these conflicts or tell you about them and, in some cases, reduce them.

Our FAs generate income in one of the following ways:

• Product sales commissions or a percentage of mark up or mark down

• Trailers earned on investment product sales

• Account maintenance fees

For more information on how your FA/broker generates fees, please refer to the Reg BI Disclosure Document and other fee disclosures available at the links below.