Rajiv Dayal

The following is a description of our principal fees and costs. We are paid for our services to you. For financial planning and consulting services, we are paid a lump sum or ongoing (i.e. monthly or annually) fee. For investment monitoring services, we are paid a portion of the overall asset management fee paid by you to the third-party asset manager. For investment management services, we are paid an asset management fee that is calculated as a percentage of the assets under management by us. Planning and consulting fees are assessed when you agree to engage us for the services or at the conclusion of the planning process. Investment monitoring and management fees are generally assessed on a quarterly basis. Some investment programs, called “wrap fee” programs, assess a fixed fee for certain administrative and operational services like trading costs. The Integrated Portfolio Models and some advisory programs developed by account custodians are wrap fee programs. The fees associated with wrap-fee programs will include most transaction costs and fees to a broker-dealer or bank that has custody of these assets, and therefore are higher than typical asset-based advisory fees. While we obviously must be paid for the services we provide, the fact that we are paid results in an unavoidable conflict of interest because we have an incentive to encourage you to use our services. In instances where we charge an asset-based fee we have an incentive to encourage you to increase the assets in your account because you will pay a larger fee relating to the higher asset level.

The following is a description of other fees and costs of our services. In addition to the fees and costs discussed above, you will be charged fees by the custodian where your account is located and/or the investment companies that created the products you are invested in. These fees include account maintenance fees, fees related to mutual funds and variable annuities, and other transactional fees and product-level 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.

For additional information, please see our most recent Disclosure Brochure, Code of Ethics, Privacy Policy, and account forms.

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. For example, when you invest in one of the Integrated Portfolio Models, a fee is paid by you in excess of the management fee charged by our financial advisor. This fee is intended to cover the administrative and operational cost of maintaining the portfolio model. Since this fee is paid to us, and is in excess of the financial advisor’s fee, it creates a conflict of interest that incentivizes us to encourage you to invest in Integrated Portfolio Models. Some third parties such as investment sponsors (i.e. mutual fund and insurance companies) help defray the costs of financial advisor training and meetings. This financial support creates a conflict of interest inasmuch as it creates an incentive for us to recommend or sells certain investments.

Our financial advisors are independent contractors. Their primary source of revenue relating to services they provide to you is a percentage of the fees paid by you to us. In addition, financial advisors may receive waivers of fees, lump sums of compensation under forgivable and repayable promissory notes, or non-cash compensation such as free or reduced cost attendance at training events and seminars. Some of our advisors are registered representatives of an SEC registered broker-dealer and/or insurance agents. Your advisor may offer you securities brokerage services through the broker-dealer, insurance services through third parties or investment advisory services through us. Brokerage, insurance and investment advisory services are different, and the fees we, insurance organizations and broker-dealers, charge for those services are different. In particular, your advisor may earn additional transaction-based compensation and have additional conflicts of interest as a result of providing brokerage or insurance services. You are encouraged to learn by reviewing the broker dealer’s relationship summary and having a discussion with your advisor about brokerage, insurance and advisory services.