A Smarter Way to Invest Inc

Item 5 - Fees and Compensation

A. Fee Schedule and How We Are Compensated
Smarter Way receives compensation for its investment advisory services provided to RIAs under the
service structures described in Item 4, including SMA/sub-advisory model management, TAMP

services, Signal Provider services, and retirement plan services. Smarter Way’s fees are generally
calculated as a percentage of assets associated with SWS or, for Signal Provider arrangements, a
percentage of assets the engaging RIA identifies as utilizing and/or being influenced by the signals.

Smarter Way’s advisory fee does not exceed 1.00% annually of the applicable asset base, unless
otherwise agreed to in writing with the engaging RIA. Fees are negotiable and may vary based on factors
such as the service structure selected (e.g., SMA vs. TAMP), scope of services, operational
requirements, total assets committed by the RIA, and other relationship factors.

The specific fee rate, fee base, valuation methodology, billing cadence, and payment terms for each
engagement are set forth in the agreement(s) between Smarter Way and the engaging RIA (the “RIA
Agreement”) and associated program documentation.

In certain cases, Smarter Way may charge the engaging RIA an additional technology fee of $35 per open
account per year for accounts utilizing Smarter Way TAMP or SMA services (or related technology
access), as set forth in the RIA Agreement. Unless otherwise agreed, this fee may be billed quarterly in
advance based on the number of open/linked accounts as of the applicable billing date. The RIA
Agreement governs whether the RIA pays this fee directly or passes it through to end-clients.

B. Payment of Fees; Fee Deduction; Billing Frequency
Smarter Way supports multiple billing and payment structures depending on the arrangement selected
by the engaging RIA and the custodian/platform capabilities. Smarter Way’s contractual relationship is
with the engaging RIA; however, certain billing structures may involve fee deduction from end-client
accounts through a qualified custodian/platform based on authorizations maintained by the RIA and/or
the custodian/platform.

RIA bills and remits Smarter Way’s fee
In certain arrangements (including Signal Provider services and some model/TAMP arrangements), the
engaging RIA bills its client(s) and remits Smarter Way’s fee to Smarter Way pursuant to the RIA
Agreement. In these arrangements, Smarter Way does not control whether, or how, the RIA passes
Smarter Way’s fee through to end-clients.

Smarter Way facilitates billing
In other arrangements, Smarter Way may facilitate billing through the custodian/platform, either by (i)
billing a single combined fee that includes both Smarter Way’s portion and the RIA’s portion and

remitting the RIA’s portion back to the RIA, or (ii) billing only Smarter Way’s portion while the RIA bills
separately.

Billing frequency
Billing frequency and methodology are set forth in the RIA Agreement and/or program documentation.
Where Smarter Way facilitates billing, fees are generally billed quarterly in advance (unless otherwise
agreed). Where the RIA bills and remits Smarter Way’s fee, billing frequency and method are determined
by the RIA’s end-client agreements and billing practices.

Fee deduction and custody
Where fees are deducted directly from end-client accounts, fee deduction occurs pursuant to
authorizations maintained with the qualified custodian/platform and/or maintained by the engaging RIA
as part of end-client account documentation. To the extent Smarter Way’s advisory fees are deducted
directly from end-client accounts, Smarter Way may be deemed to have limited custody under
applicable regulations, as further described in Item 15.

C. Other Fees and Expenses
Smarter Way’s advisory fees are separate from fees and expenses charged by custodians, platforms,
and underlying investments. End-clients may incur additional costs including, for example: custodial
fees, transaction charges, platform or account fees, wire/transfer fees, and internal fees and expenses
of mutual funds and ETFs. These costs reduce investment returns and are generally not paid to Smarter
Way unless otherwise disclosed in applicable agreements.

End-clients will also incur brokerage and other transaction costs in connection with the purchase and
sale of investments. Please see Item 12 (Brokerage Practices) for additional information regarding
brokerage and transaction costs.

D. Prepayment of Fees; Refunds; Termination
In certain arrangements, fees may be billed in advance (for example, where Smarter Way facilitates
billing quarterly in advance). In other arrangements, fees may be billed in arrears, as set forth in the RIA
Agreement and/or program documentation.

If fees are billed in advance and the applicable engagement is terminated before the end of a billing
period, unearned fees are generally refunded on a pro-rated basis through the termination effective
date, subject to custodian/platform processing. If fees are billed in arrears, Smarter Way generally

assesses a final pro-rated fee through the termination effective date. Where the engaging RIA bills and
remits Smarter Way’s fee, any client-level refunds or adjustments (if any) are determined by the RIA’s
end-client agreements and billing practices; Smarter Way’s compensation in those arrangements is
governed by the RIA Agreement.

Where Smarter Way facilitates billing, Smarter Way may perform pro-rata billing adjustments and/or
rebates in connection with new accounts and material cash flows (generally contributions or
withdrawals of $10,001 or more) during a billing period, subject to custodian/platform billing
capabilities and as reflected on applicable fee notices.

End-clients may incur additional custodial or transaction costs in connection with transfers or
termination imposed by the custodian/platform, and Smarter Way does not receive compensation from
such fees.
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Item 7 - Types of Clients
Smarter Way primarily provides investment advisory services to registered investment advisers (“RIAs”)
and, where applicable, to retirement plan fiduciaries/sponsors under the arrangements described in
Item 4. Through these relationships, Smarter Way’s strategies may be implemented in accounts of the
RIA’s end-clients, which may include individuals and families, trusts, estates, businesses, and
retirement plans.

Smarter Way’s strategies are generally made available for accounts with a minimum of $250,000 in
assets allocated to SWS (or such other minimum as specified in the applicable RIA agreement and/or
program documentation). Smarter Way may, in its discretion, make certain strategies available for
smaller portfolios or waive minimums on a case-by-case basis.