Bennett John Nadworny

For Investment Management Services, you will be charged an ongoing management fee based on the assets under management in accordance with the fee schedule presented in your client agreement. Fees are negotiable based on factors such as the client’s financial situation and circumstances and the amount of assets under management. When you are charged an asset-based fee, the more assets that are in the account, the more you will pay in fees. This creates an incentive to encourage you to increase the amount of assets invested in these accounts. In addition to the fee(s) above, you will be responsible for certain charges imposed by the custodian and/or broker, including transaction fees, custodian fee (e.g. wire fees), and internal fees related to mutual funds. Other than one private fund, we do not typically charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client).

Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, third party investments and other third parties such as fees charged by managers, sub-advisers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds exchange traded funds, hedge funds, private equity funds and other pooled investment vehicles also charge internal management fees, which are disclosed in a fund’s prospectus or other offering materials.

If you are only engaging our wealth planning services, SFA charges a fee for preparing a Plan. This fee is negotiable and is specified in an engagement letter. SFA offers Trustee Support Services. There is a setup fee and ongoing fees. Fees are in addition to investment management fees described above and vary by client based on scope of the engagement, and the complexity of the financial situation, among other factors.

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 about our fees, please reference Items 5 and 7 of our Brochure at Form ADV 2A.

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.

• Our firm uses non-directed client commissions (e.g. “soft dollars”) to receive investment related research and services from our custodians. These services provide an incentive to recommend the use of these custodians.

• We have agreements with unaffiliated third parties and our custodians to solicit clients on our behalf. In exchange, we compensate them. Your fees are not increased due to this.

• Our custodians provide benefits related to trading, research, compliance, and marketing amongst others. These services provide an incentive to recommend the use of these custodians

• SFA has an arrangement with an affiliated company to provide insurance solutions. The affiliation creates a conflict as there is a benefit to referring. Clients are under no obligation, contractually or otherwise, to buy insurance products. This is defined in our Form ADV.

• Proprietary Products: We may recommend that you invest assets in a pooled investment vehicle which we manage. One of these vehicles (the ZCA Focus Fund) pay us performance fees from this fund and therefore have an incentive to recommend it to you.

• Third-Party Payments: We do not receive any compensation from third-party issuers or investments.

For additional information about our obligations as an investment adviser and our conflicts, please reference Item 10 of our Firm Brochure at Form ADV 2A.

Our financial professionals are paid a salary plus bonuses based on company, team, and individual performance, which includes metrics like client retention and referrals that is derived from revenue the firm earns from the financial professional’s advisory services and recommendations.