Aspetuck Financial Management LLC

FEES AND COMPENSATION

Investment Advisory Fee

  Risk Managed Portfolio Program Fee Schedule A:
  AUM                                            Fee
  First $1,000,000                               0.85%
  Next $3,000,000                                0.70%
  Thereafter                                     0.65%

  As a participant in the Program, Client will pay an annualized Investment Advisory Fee, in
  accordance with Schedule A which is in effect for new clients effective January 1, 2018.
  Aspetuck charges its fee based on a tiered or “blended rate” fee structure. This means that
  AFM may apply multiple percentage rates to determine our fee depending on the amount of
  assets under our management in your advisory account. For example, if you have assets under
  management of $4,000,000, then AFM will charge the first $1,000,000 at 0.85% and the next
  $3,000,000 at 0.70%. Clients may request that AFM household their accounts for purposes of
  calculating fees.

  Legacy Fee Table (Prior to January 2018).
  AUM                          Fee
  First $500,000               1.25%
  Next $500,000                1.00%
  Thereafter                   0.70%

  Advisory fee may also be subject to negotiation at Aspetuck’ s discretion depending upon many factors,
  including size of the accounts. Lower fees for comparable services may be available from other sources.

 The Investment Advisory Fee is due and payable quarterly, in advance, and is based upon the
 market value of the client’s account as determined by the custodian as of the close of business
 on the last day of the previous calendar quarter. Fees for the initial quarter are adjusted pro-
 rata based upon the number of calendar days remaining in the calendar quarter. Fee payable
 for assets deposits after the inception of a quarter will be prorated based on the number of
 days remaining in the quarter. The Investment Advisory Fee may be deducted from the client
 account or paid by check. Black Diamond fee invoice reports and Brokerage/Custodian
 statements may slightly differ in some cases by trade transactions that do not settle until
 after the statement date which occurs after close of business on the last business day.

  Client may have multiple accounts as part of the Program and may elect to have Advisory fees
  debited from one previously selected Account.

  If an Account is liquidated, due to a termination notice, proceeds will be payable to Client upon
  settlement of all transactions in the Account and any related fees or transaction costs due to

  liquidation. Client will be entitled to a pro-rated refund, payable to the Account where debit
  occurred, of any pre- paid quarterly Investment Advisory Fee based upon the number of days
  remaining in the quarter after the termination date. No advisory relationship exists between
  Adviser and Client when Agreement is terminated.

  401(k) Plan Participant Accounts:

  401(k) Plan Participant fees are due in arrears and calculated and invoiced by Plan Record
  Keeper/Administrator.

  CollegeAmerica 529 Plan Accounts:

  The RMP Program also manages CollegeAmerica 529 Plan accounts offered by American
  Funds and College America. CollegeAmerica 529 Savings Plan advisory fee is a flat fee of
  0.65% for new account effective January 2018. Investment Advisory fees are deducted
  from client’ s 529 Plan account by American Funds in arrears at quarter end for F2 shares.

ERISA 3(38) Manager Fee

Investment management fee ranges from 0.67% to 0.25% depending on several factors: number
of plan participants, assets in plan, size of company, etc.

Clients are responsible for the payment of all third-party fees (i.e., custodian fees, commissions,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from
the fees and expenses charged by AFM. Please see Item 12 of this brochure regarding broker-
dealer/custodian.

Neither AFM nor its supervised persons accept any compensation for the sale of securities or
other investment products, including asset-backed sales charges or service fees from the sale of
mutual funds.

PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT

 Not applicable

TYPES OF CLIENTS

AFM generally provides advisory services to the following types of clients: Individuals, Trusts, Corporations or
Business Entities, and Pension and 401(k)/Profit-Sharing Plans. The minimum account size is $50,000 but
exceptions are made depending on client circumstances, and financial planning needs. For example, starting
an IRA account with an initial contribution or a 529 Plan account.

METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

  AFM manages four types of model portfolios: Aggressive, Moderate, Conservative, Risk Averse.

  AFM has a professional portfolio construction process based on Modern Portfolio Theory, basic
  investment principles, and economic/market analysis. Generally, assets are allocated globally among
  equities, bonds, cash-equivalents, real estate securities, and commodity ETFs and individual securities
  using strategic asset allocation guidelines. In general, AFM believes it is a prudent investment practice to
  diversify among Electronically Traded Funds (ETFs), to reduce volatility and specific business risk
  associated with individual securities (individual stocks and bonds). It is our belief that it is easier to diversify
  and manage investment risk, return, and income from your account by investing among ETFs. Studies
  have shown that non-diversified approaches that use a limited number of individual securities increase the
  risks of producing streaky results. Our goal is to seek consistent results over time. With that said, AFM also
  believes that limited investing in individual securities can enhance income, return, and risk management
  of accounts. For example, at times, investing in a quality dividend paying stock, at the right price, can
  enhance account income, lower risks, and improve returns versus buying an overvalued lower yielding
  ETF. Our equity investment style is characterized as an Equity Income approach and Growth-At-
  Reasonable-Price approach towards stock selection. Generally, AFM invests in equities paying and growing
  dividends, which offer appreciation potential, and trade at a reasonable valuation or quality companies
  growing sales trading at reasonable valuations. Moreover, in general, AFM prefers quality companies
  with healthy fundamentals over speculative companies with poor fundamentals.

  AFM actively manages portfolio characteristics to manage risk, income, and return. AFM has a robust
  research process to decide on tactical adjustments. AFM are top-down macro investors. Macro-economic
  themes such as inflation, and economic growth drive asset allocation decisions. This process involves an
  assessment of global economic and market conditions, and investment sector fundamentals. AFM
  monitors numerous cyclical economic and market factors that impact the performance of securities.
  These factors encompass monetary policy, fiscal policy, inflation trends, credit markets, interest rate
  trends, economic growth, earnings growth, employment, consumer spending, U.S. dollar, yield spreads,
  investor and consumer psychology, technical indicators, etc. Upon deciding which areas of the global
  market offer the best risk/income/growth proposition, AFM employs research driven, securities
  selection process to execute our investment allocation strategy.

  In our analysis, AFM utilizes information provided by numerous private and public research providers. For
  instance, AFM use data provided by the Federal Reserve, Department of Labor, Standard & Poor’s, FactSet,
  Ned Davis Research, Charles Schwab & Co., major asset management firms, CNBC, Barron’s, Wall
  Street Journal, Black Diamond Inc. Bespoke Investments, Bloomberg, etc. AFM also uses independent
  third-party research from multiple sources to evaluate equity and fixed income securities.

  Risk Management

  Investing in securities involves the risk of loss that the client should be prepared to bear. AFM seeks to
  manage risk by adjusting your account asset allocation and investment holdings based on economic and
  current market conditions and investment analysis. What is managed?

  □   Asset Allocation is our primary way of managing investment risks– do not put all your eggs in one
      basket like S&P 500 Index. Instead, asset allocate among major assets classes to manage
      investing risks. Conservative portfolio strategies will have less exposure to equity markets.

    than aggressive strategies. Moreover, RMP Program adjusts asset allocation as market conditions
    change through economic cycle.
□   Foreign Allocation – exposure to foreign markets. Invest globally as a long-term diversification
    strategy, however, partially hedge currency risks.
□   Capitalization – exposure to Large, Mid, and Small sized companies
□   Sector Orientation – cyclical and defensive exposure
□   Credit Quality – adjust quality of fixed income investments as credit conditions change.
□   Bond maturity – adjust portfolio duration to manage interest rate risk and income by changing
    deployment of assets over long term, intermediate, and short term.
□   Securities selection – specific sectors and mostly buy quality dividend growers/payers of
    large-cap companies at reasonable valuations.
□   Being sensitive to investment valuations. Overpaying for an investment could result in a loss or
    lower return.
□   Generally, limit each investment (ETF, security) position in your portfolio.
□   Generally, limit the concentration in an investment sector.
□   Investing a minor part of your portfolio in “low correlation” investments to a major part of your
    portfolio.
□   Periodically rebalance asset allocation to manage portfolio risks or adjust assets by selling what
    AFM believes are overvalued investments and invest proceeds into what AFM believes is unvalued
    investment opportunity.
□   Raising cash-equivalent levels as the market valuations become excessive and or market conditions
    begin to deteriorate.
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